New Local Plan: Spatial Options Document 2021

ROCHFORD NEW LOCAL PLAN: SPATIAL OPTIONS CONSULTATION- SUBMISSION OF REPRESENTATIONS ON BEHALF OF SOUTHERN & REGIONAL DEVELOPMENTS LIMITED
Claremont Planning Consultancy have been instructed by Southern and Regional Developments Limited to prepare and submit representations to the new Local Plan: Spatial Options consultation.
Southern and Regional Developments are in control of two sites within the Rochford District; the land at Lower Wyburns Farm, Rayleigh, and Sutton Road, Rochford, with both sites previously promoted to the Council through the 2018 Call for Sites exercise for the emerging
Local Plan. For clarity, it has therefore been considered prudent to prepare and submit representations to the Spatial Options consultation separately considering each site separately.
As such, please find the following sets of representations enclosed:
• Lower Wyburns Farm representations to Spatial Options- Location Plan and Illustrative
Masterplan enclosed.
• Sutton Road representations to Spatial Options - Location Plan enclosed
We trust that these representations are clear and will be duly taken into consideration, however, if Southern and Regional Developments or Claremont Planning can assist with providing any further information in relation to the sites at Lower Wyburns Farm and Sutton Road, or the content of the representations submitted, please do not hesitate to contact me on the details below.

Rochford District Council – Lower Wyburns Farm, Rayleigh
Representations to the Spatial Options
1. Introduction
1.1. On behalf of Southern and Regional Developments Ltd, Claremont Planning Consultancy has been instructed to prepare and submit representations to the Spatial Options consultation being undertaken by Rochford District Council to inform the emerging Local
Plan.

2. Strategy Options
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?

2.1. Claremont Planning, on behalf of Southern and Regional Development’s Ltd, are supportive of the settlement hierarchy proposed. The identification of Rayleigh as the only ‘Tier 1’ settlement within the District is supported, finding this proportionate to the settlement’s larger population and comprehensive service base, which is of both local and regional prominence. The proposed settlement hierarchy correctly recognises the strategic location of Rayleigh which affords the settlement a functional relationship with the adjacent
Southend, Basildon, Chelmsford, and London Districts.
2.2. It is recommended that the spatial strategy advanced by the emerging Local Plan be strongly informed by the proposed settlement hierarchy. The proposed hierarchy of settlements evidences that Rayleigh benefits from a wide range of retail, employment, and community facilities and therefore represents a highly sustainable location for development. In accordance with the provisions of Paragraph 16 of the National Planning
Policy Framework (NPPF), development plans should be prepared with the objective of contributing to the achievement of sustainable development. As such, it is advisable that the overall distribution of growth is informed by this imperative, and a larger quantum of
growth apportioned to those settlements which are identified by the hierarchy as being most sustainable, chiefly Rayleigh. To accommodate the necessary growth of Rayleigh a full review of the settlement boundary should be undertaken through this plan review process, with Green Belt release of suitable sites promoted to ensure that Rayleigh can accommodate the level of growth its position in the settlement hierarchy requires.

Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
Strategy Option 1: Urban Intensification
2.3. It is advised that Strategy Option 1: Urban Intensification is not advanced on its own. The current standard method identifies a housing requirement of 7,200 dwellings for the district across the next 20 years, however the consultation document establishes that only 4,500 new dwellings can be delivered through Option 1. Paragraph 35 of the NPPF identifies that Plans must provide a strategy which as a minimum seeks to meet the area’s objectively assessed needs in order to be found sound. Delivering development through Strategy Option 1 will result in a substantial shortfall in housing delivery and will unlikely be considered sound by the Inspector when the Plan is examined.
Strategy Option 2: Urban Extensions
2.4. It is recognised that Strategy Option 2, which seeks to spread development across several development sites of between 10 and 1,500 homes adjoining existing towns and villages, could deliver a sustainable distribution of housing growth. The dispersal of urban extensions based on the settlement hierarchy is supported, where this would see growth delivered at the most sustainable settlements in the District. In accordance with the proposed settlement hierarchy, the allocation of urban extensions at Rayleigh, the District’s largest and most sustainable settlement, should be prioritised if this option is taken forward. When considering urban extensions, they should not prohibit the appropriate review of a settlement’s boundary and site releases from the Green Belt for development elsewhere. Co-ordinating urban extensions that are typically large scale developments
alongside smaller site allocations will facilitate the delivery of small to medium sites as advised by the NPPF at Paragraph 69; which will enable the continual supply of housing through a maintained trajectory.
Strategy Option 3: Concentrated Growth
2.5. Concentrating growth in one or more locations of 1,500+ dwellings, as promoted within Strategy Option 3 is not supported on its own at this time. Large allocations and the development of new settlements, by virtue of their complexity and infrastructure requirements, have much longer lead in times for delivery and therefore would be likely to contribute towards meeting housing needs towards the end of the Plan period and beyond.
As such, pursuit of this Strategy Option alone will not deliver sufficient housing to meet the Authority’s housing needs in the earlier years of the Plan, leaving the Authority vulnerable to speculative development which is not Plan lead particularly if delays in the delivery of
these allocations arise. Topic Paper 9: Housing prepared in support of the Spatial Options Consultation 2021 illustrates that over the last 10 years Rochford’s historic rate of housing delivery is 227 dwellings per annum, requiring an uplift of around 60% in annual housing
completions to meet the local housing need identified for the new Local Plan. The Authority should note that paragraph 69 of the NPPF advises against the concentration of growth as proposed within Strategy Option 3, instead recommending that development plans should seek to accommodate at least 10% of their housing requirement on sites no larger than one hectare. Given the uplift in housing delivery which will be required to meet housing need, it would be prudent that the Council also consider the allocation of small and
medium sized sites, such as the promoted land at Lower Wyburns Farm, which can contribute directly to the next 5 year supply and be delivered quickly, making a more
immediate contribution to housing supply alongside this Strategy.
Strategy Option 4: Balanced Combination
2.6. Strategy Option 4 advances a balanced combination of the various Strategy Options presented, including making the best use of urban capacity (Option 1), building on one or two large growth areas (Option 3), and a number of smaller urban extensions (Option 2).
Claremont Planning strongly recommend that the Authority pursue the blended approach promoted within Option 4. It is considered that Option 4 represents the most sustainable means of meeting the District’s housing requirement, by maximising sites available within the existing urban area, and delivering smaller urban extensions at sustainable locations in accordance with the proposed settlement hierarchy. Paragraph 69 of the NPPF establishes that a blended approach which allocates small, medium, and larger sites for development is advisable, ensuring that any potential delays in the delivery of larger allocations do not
adversely affect housing delivery in the District.
2.7. Paragraph 35 of the NPPF sets out the tests for ‘soundness’ of development plans, establishing that plans should, as a minimum, seek to meet their areas objectively assessed housing need and be informed by agreements with other authorities so that any unmet need from neighbouring areas can be accommodated where it is practical to do so. The southern and northern parcels of the land promoted by Southern and Regional
Developments at Lower Wyburns Farm have been recognised by the Council within their Site Assessment Paper 2021, with references CFS068 and CFS069 respectively; for their potential to deliver growth through Option 2, small urban extensions. Claremont Planning
strongly support the Council’s recognition of the land’s potential and note that the land occupies a highly sustainable location adjacent to the District’s only Tier 1 settlement.
Furthermore, the promoted site should be recognised as a suitable location which could contribute towards unmet need arising from neighbouring authorities due to its close geographical proximity to adjacent districts, particularly to the Castle Point Borough and
Southend-on-Sea Districts, whilst also benefitting from a close functional relationship these due to its proximity to the strategic highway network, namely the A127.

3. Spatial Themes
Q9. Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and
coastal change wherever possible? How can we best protect current and future communities from flood risk and coastal change?

3.1. National policy, chiefly paragraph 161 of the NPPF, is clear in its expectations that development plans apply a sequential, risk-based approach to the location of development which includes taking into account all sources of flood risk as well as current and future
impacts of climate change. As such, it is agreed that a sequential approach to flood risk and coastal change should be adopted by the Plan, and this would be a sound approach that is consistent with national planning policy. As recognised by the Council, much of the
District is affected by Flood Zone 3 with flood risk likely to be subject to coastal change as a result of climate change. As such, it is recommended that development opportunities within areas at lower risk of flooding are fully considered by the Authority. Approaching flood risk and coastal change sequentially would also accord with the proposed settlement hierarchy, concentrating development at the main settlements of the District, including Rayleigh which are the areas within the District at lower risk of flooding.
3.2. The land at Lower Wyburns Farm, Daws Heath Road represents one such suitable location for development if the sequential approach to flood risk is adopted. With respect to the parcel of land south of Daws Heath Road, only a very small area along Daws Heath Road, is affected by Flood Zone 2. With respect to the promoted parcel of land north of the road, this is more heavily influenced by flood risk, being completely covered by Flood Zones 2 and 3. Previous representations submitted to the Council through the SHLAA/Call for Sites process by Claremont Planning have considered the flood risk present on the site at length and it is advanced that the flood zone 3 areas should be removed from consideration for development and instead contribute toward public open space provision and ecological enhancement measures. Any development on the northern parcel should be focused upon redeveloping the existing dwelling on the site, away from the flood prone
areas and towards the frontage with Daws Heath Road.
3.3. When assessing the flood risk of the promoted land at Lower Wyburns Farm within their initial site assessments, the Council also recognise that the majority of the promoted land is at low risk of flooding, scoring the northern and southern parcels of the site as 3 and 4 respectively for flood risk on a scale on for which 5 represents the best performing sites.
Given that the vast majority of the promoted land at Lower Wyburns Farm south of Daws Heath Road is located within Flood Zone 1, and the Council’s recognition that the site performs strongly in respect of flood risk; Claremont Planning consider that the
development of this land would be in accordance with the recommended sequential approach to flood risk in the Plan.

4. Housing for All
Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes, and tenures of housing?

4.1. Meeting the need for different types, sizes, and tenures of housing by requiring a suitable or negotiable mix of housing that is responsive to the type and location of development, as promoted by Option 2, is recommended by Claremont Planning. It is considered that this represents the most pragmatic approach to meeting these needs by providing flexibility in the market to ensure that the right types of homes are delivered in the right locations. Applying a blanket housing mix policy would fail to recognise that some types of land are
more well suited to certain forms of development. For example, both the Housing Topic Paper 2021 and 2017 SHMA establish that there is the greatest need for small and midsized semi-detached and detached dwellings. Claremont Planning consider that the release of Green Belt land, including the site at Lower Wyburns Farm should be strongly considered by the Council whereby the release of this land will both assist the Council in
meeting their overall housing need and facilitate the delivery of an appropriate mix of housing. In particular this will assist delivery of family sized housing which is better suited to delivery on greenfield land than constrained urban sites.

5. Green and Blue Infrastructure
Q32. With reference to the options above, or your own options, how do you feel we can best deliver quality green and blue infrastructure network throughout the Plan?
5.1. The Green and Blue Infrastructure Topic Paper 2021 identifies that previous housing and economic growth throughout South Essex has not been sufficient to meet the region’s growth potential. As such, Claremont Planning maintain that although delivering quality
green and blue infrastructure is valuable, this must be balanced against the region’s need for growth. It is therefore recommended that identifying general objectives for strategic green and blue infrastructure through the plan (Option 2) is pursued by the Authority, with this Option relying on other existing allocations, such as open space, local green space, and local wildlife site designations to deliver improvements. The suggestion identified within the Topic Paper that the Plan could still contain policies that help to deliver improvements to green and blue infrastructure, including the capture of funding through planning obligations associated with development is recommended to be advanced
alongside this approach. Advancing Option 2 would continue to promote the delivery of improvements on site where appropriate, without constraining the ability of development to make the most effective use on land by requiring on-site improvements to be delivered.
Moreover, it is not considered that detailed, site-specific policies are relevant for inclusion within a strategic plan of this nature where national planning policy establishes in Chapter 3 of the NPPF the role that strategic policies should play, which is to set the overall strategies for the pattern, scale and design quality of places. As such, policies relating to site specific provision of green and blue infrastructure would be more appropriately dealt
with through the preparation non-strategic level Plans and Policies such as those in Neighbourhood Plans.
5.2. The Green and Blue Infrastructure Topic Paper 2021 also establishes that the connectivity of green and blue infrastructure is challenging, with many poor green and blue linkages between towns, villages, rural areas and waterfronts. Whilst Option 3, requiring certain new
developments to provide local green and blue infrastructure on-site, may increase the quantum of green and blue infrastructure throughout Rochford, there is risk that this may worsen the connectivity of these spaces through their piecemeal development.
Contrastingly, securing funding through planning obligations as part of Option 2 could deliver strategic improvements to this network to be made in accordance with a wider vision for the area. This would represent a more effective and deliverable strategy, meeting that criteria for soundness as identified in the NPPF.

6. Town Centres and Retail
Q46. With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley?
How can we also ensure our village and neighbourhood centres remain vibrant?
6.1. Claremont Planning support the ambition of Options 5 and 10 in their recognition that delivering a suitable mix of uses including residential development is essential in
continuing to support the vitality and viability of town centres. It is considered important however, that the Council recognise the importance of allowing settlements to expand through new development outside of the existing settlement boundary, as this can allow the population of settlements to grow. This in turn can increase footfall to existing shops and services, and enhance the vitality and viability of these settlements, especially where good pedestrian connectivity to the town centre is present. Whilst it is recognised that the
consultation document identifies that town centres within the District have not suffered declines in footfall as acutely as national trends would indicate, further development and growth at a settlement could ensure that town centres remain sustainable in the future.

7. Green Belt and Rural Issues – Plan Objective 20 (p.69-70)
7.1. The recognition that the release of Green Belt land will be required to meet housing needs through the emerging Plan is strongly supported. It is agreed that the Council can demonstrate the exceptional circumstances necessary to justify this release, in accordance with paragraph 141 of the NPPF. The Consultation Document has sought to establish that a spatial strategy reliant on urban intensification will not deliver sufficient housing to meet the Council’s objectively assessed need and confirms that early discussions with adjacent authorities has not identified capacity for accommodating unmet need arising from Rochford. As such, it is agreed and supported that the emerging Local Plan will be able to
demonstrate the exceptional circumstances necessary to justify the release of Green Belt land.
7.2. The Rochford District and Southend-on-Sea Joint Green Belt Study (February 2020) forming the evidence base to this consultation contains detailed site assessments that identify the contribution made by promoted sites to the purposes of the Green Belt. Within
this report, the land at Lower Wyburns Farm was assessed as making a strong contribution to the purposes of the Green Belt, finding that the site presents a strong openness and has a closer relationship with the surrounding countryside than the urban area. Likewise, the initial assessment proformas prepared by the Authority also rated the identified site as relatively strongly performing Green Belt. These conclusions are refuted and it is considered that these assessments failed to recognise several key features of the promoted land which diminish its contribution to the Green Belt. Notably, assessments of the land around the site have failed to identify that both the north and south parcels of the site are currently in use and developed; with the original farmhouse and livery stables in the southern parcel alongside a range of buildings and yards that accommodate B2 Industrial uses with external storage areas and further Sui Generis horticultural and
residential uses located within the northern parcel. As such, a large quantum of the promoted site’s area represents previously developed land and should be prioritised for development.
7.3. The Joint Green Belt Study however establishes that the environmental and sustainability effects of development need to be considered when releasing land from the Green Belt, where it may be that the most sustainable locations for development may not be
appropriate or sustainable, with this pragmatic approach to Green Belt release strongly supported by Claremont Planning where it accords with the provisions of paragraph 142 of the NPPF. Specifically, paragraph 142 of the Framework recommends that plans should give first consideration to land which is previously developed and/or well served by public transport when considering Green Belt release. It has been established that a proportion of the land promoted by Southern and Regional Developments at Lower Wyburns Farm
represents previously developed land, as previously recognised in the Council’s 2017 SHELAA assessment of the southern parcel (CFS068), with built form existing on the southern parcel of the site in particular with a variety of B2 industrial sheds alongside an established concrete hardstanding and occupied by structures extending up to two stories in height, obscuring any view of the wider countryside and significantly reducing the land’s openness. Moreover, the industrial units occupying the land at present host a variety of established uses, including a lawn mower repair shop and vehicle servicing, alongside a camping and caravan site, whilst the northern parcel of land is used as a plant nursery. As
such, both parcels benefit from established activity and transport movements further reducing openness characteristics attributed to the site.
7.4. At present the Green Belt Study does not adequately consider the characteristics of the site with respect to its established uses, built form and recognitions as previously developed land. This is demonstrated through the Parcel Assessments included in the Green Belt Study, with the promoted land included incorrectly within Parcel 21 alongside undeveloped farmland. The parcel sizes identified through the study vary considerably in
shape and size, with specific characteristics of land informing the parcel sizes. An example of this and the resulting assessment of Green Belt factors is Parcel P29 that covers the land off Rayleigh Down Road and The Drive, where residential buildings and area of external caravan storage alongside/ horticultural/agricultural buildings have been recognised within a smaller parcel area and assessed as having less contribution to
Green Belt as a result. This approach of applying a smaller parcel should also have been identifeid for the land at Lower Wyburns Farm, which would have enabled its assessment separately from the woodland, playing fields and pasture that makes up the rest of parcel
21 to the east. The Green Belt Study undertaken has therefore not allowed for the appropriate assessment of edge of settlement sites that would otherwise be considered as sustainable allocation options and be taken forward for further consideration through the
Local Plan process.
7.5. The reduced openness and lack of rural character afforded by the existing structures on site reduces the land’s contribution to the Green Belt considerably. In accordance with the principles established by the Joint Green Belt Study, alongside the reduced contribution of
the land to the purposes of the Green Belt, the highly sustainable location of the site adjacent to Rayleigh and the accessibility of local services and facilities from the site, should also ensure that the land at Lower Wyburns Farm is identified as a suitable candidate for Green Belt release.

Q56b. With reference to Figure 44 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses?
How could that improve the completeness of Rayleigh?
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community Infrastructure [open space, education, healthcare, allotments, other]
4. Other

8.2. Promoted sites CFS068 and CFS069 (Land at Lower Wyburns Farm) identified on Figure 44 should be made available for residential development. Although land at Lower Wyburns Farm promoted by Southern and Regional Developments is not identified on the walking completeness score map presented within the ‘Complete Communities’ Topic Paper, the site is located adjacent to areas afforded attributed a walking completeness score of 8-10 showing that reasonable levels of services and facilities are located within the ‘walking catchment’ of the land. Notwithstanding this, it is recommended that the
Council be pragmatic in applying walking completeness scores where the Topic Paper confirms that being located outside of the comfortable walking catchment for a specific facility does not mean that the facility is inaccessible. This assertion is particularly relevant
for Rayleigh, where the Topic Paper establishes that 56% of the settlement is located within the walking catchment of a frequent bus service. A review of the promoted land’s context confirms that the site is located within a 5 minute walk from existing bus stops sited along the Eastwood Road. These bus stops provide very frequent services to a range of destinations including, Southend-on-Sea, Shoeburyness, Rayleigh, and Basildon Town
Centre. As such, Claremont Planning recommend that the Council recognises the highly sustainable location of the promoted land at Lower Wyburns Farm for residential
development, given both the variety of services and facilities located within the land’s walking catchment, and the site’s close proximity to frequent public transport services.
8.3. Moreover, the vision for Rayleigh advanced by the Consultation Document sets out the ambition to provide for a diverse range of housing which meet the needs of all in the community. The 2017 Strategic Housing Market Assessment (SHMA) establishes that both within Rochford, and across the South Essex region, the greatest additional demand for housing will be generated by households requiring family housing with three bedrooms. As such, it is considered that the release of the land at Lower Wyburns Farm from the Green Belt, and its allocation for residential development can strongly contribute to delivering housing to meet this need where greenfield land is considered to be more appropriate for
the delivery of family-sized housing. It is also advised that the Authority acknowledge the strategic location of the land at Lower Wyburns Farm in close proximity to the District boundary and connection to the A127 as a location which may be appropriate to meet any unmet need for family housing arising from the wider South Essex region.
8.4. It has been established that Rayleigh benefits from high levels of completeness, with a large percentage of the settlement located within the walking catchment of education, sport, leisure, and health facilities however, the ‘Complete Communities Topic Paper’ identifies that only 18% of Rayleigh is located within the walking catchment of green infrastructure. Previous representations made to the Authority promoting the land at Lower Wyburns Farm have identified that the site’s development will include provision of an area of public open space to the north west of the site. As such, it is considered that the allocation of the site will both continue to ensure that development at Rayleigh is located in the most sustainable locations, that are areas within the walking catchment of a good range of services and facilities, whilst also seeking to address deficiencies in green infrastructure provision in Rayleigh.
Enclosed: Site Location Plan: Lower Wyburns Farm, Daws Heath Road, Rayleigh
:Dwg SK001 Illustrative Masterplan

ROCHFORD NEW LOCAL PLAN: SPATIAL OPTIONS CONSULTATION- SUBMISSION OF REPRESENTATIONS ON BEHALF OF SOUTHERN & REGIONAL DEVELOPMENTS LIMITED
Claremont Planning Consultancy have been instructed by Southern and Regional Developments Limited to prepare and submit representations to the new Local Plan: Spatial Options consultation.
Southern and Regional Developments are in control of two sites within the Rochford District; the land at Lower Wyburns Farm, Rayleigh, and Sutton Road, Rochford, with both sites previously promoted to the Council through the 2018 Call for Sites exercise for the emerging
Local Plan. For clarity, it has therefore been considered prudent to prepare and submit representations to the Spatial Options consultation separately considering each site separately.
As such, please find the following sets of representations enclosed:
• Lower Wyburns Farm representations to Spatial Options- Location Plan and Illustrative
Masterplan enclosed.
• Sutton Road representations to Spatial Options - Location Plan enclosed
We trust that these representations are clear and will be duly taken into consideration, however, if Southern and Regional Developments or Claremont Planning can assist with providing any further information in relation to the sites at Lower Wyburns Farm and Sutton Road, or the content of the representations submitted, please do not hesitate to contact me on the details below.

Rochford District Council – Lower Wyburns Farm, Rayleigh
Representations to the Spatial Options
1. Introduction
1.1. On behalf of Southern and Regional Developments Ltd, Claremont Planning Consultancy has been instructed to prepare and submit representations to the Spatial Options consultation being undertaken by Rochford District Council to inform the emerging Local
Plan.

2. Strategy Options
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?

2.1. Claremont Planning, on behalf of Southern and Regional Development’s Ltd, are supportive of the settlement hierarchy proposed. The identification of Rayleigh as the only ‘Tier 1’ settlement within the District is supported, finding this proportionate to the settlement’s larger population and comprehensive service base, which is of both local and regional prominence. The proposed settlement hierarchy correctly recognises the strategic location of Rayleigh which affords the settlement a functional relationship with the adjacent
Southend, Basildon, Chelmsford, and London Districts.
2.2. It is recommended that the spatial strategy advanced by the emerging Local Plan be strongly informed by the proposed settlement hierarchy. The proposed hierarchy of settlements evidences that Rayleigh benefits from a wide range of retail, employment, and community facilities and therefore represents a highly sustainable location for development. In accordance with the provisions of Paragraph 16 of the National Planning
Policy Framework (NPPF), development plans should be prepared with the objective of contributing to the achievement of sustainable development. As such, it is advisable that the overall distribution of growth is informed by this imperative, and a larger quantum of
growth apportioned to those settlements which are identified by the hierarchy as being most sustainable, chiefly Rayleigh. To accommodate the necessary growth of Rayleigh a full review of the settlement boundary should be undertaken through this plan review process, with Green Belt release of suitable sites promoted to ensure that Rayleigh can accommodate the level of growth its position in the settlement hierarchy requires.

Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
Strategy Option 1: Urban Intensification
2.3. It is advised that Strategy Option 1: Urban Intensification is not advanced on its own. The current standard method identifies a housing requirement of 7,200 dwellings for the district across the next 20 years, however the consultation document establishes that only 4,500 new dwellings can be delivered through Option 1. Paragraph 35 of the NPPF identifies that Plans must provide a strategy which as a minimum seeks to meet the area’s objectively assessed needs in order to be found sound. Delivering development through Strategy Option 1 will result in a substantial shortfall in housing delivery and will unlikely be considered sound by the Inspector when the Plan is examined.
Strategy Option 2: Urban Extensions
2.4. It is recognised that Strategy Option 2, which seeks to spread development across several development sites of between 10 and 1,500 homes adjoining existing towns and villages, could deliver a sustainable distribution of housing growth. The dispersal of urban extensions based on the settlement hierarchy is supported, where this would see growth delivered at the most sustainable settlements in the District. In accordance with the proposed settlement hierarchy, the allocation of urban extensions at Rayleigh, the District’s largest and most sustainable settlement, should be prioritised if this option is taken forward. When considering urban extensions, they should not prohibit the appropriate review of a settlement’s boundary and site releases from the Green Belt for development elsewhere. Co-ordinating urban extensions that are typically large scale developments
alongside smaller site allocations will facilitate the delivery of small to medium sites as advised by the NPPF at Paragraph 69; which will enable the continual supply of housing through a maintained trajectory.
Strategy Option 3: Concentrated Growth
2.5. Concentrating growth in one or more locations of 1,500+ dwellings, as promoted within Strategy Option 3 is not supported on its own at this time. Large allocations and the development of new settlements, by virtue of their complexity and infrastructure requirements, have much longer lead in times for delivery and therefore would be likely to contribute towards meeting housing needs towards the end of the Plan period and beyond.
As such, pursuit of this Strategy Option alone will not deliver sufficient housing to meet the Authority’s housing needs in the earlier years of the Plan, leaving the Authority vulnerable to speculative development which is not Plan lead particularly if delays in the delivery of
these allocations arise. Topic Paper 9: Housing prepared in support of the Spatial Options Consultation 2021 illustrates that over the last 10 years Rochford’s historic rate of housing delivery is 227 dwellings per annum, requiring an uplift of around 60% in annual housing
completions to meet the local housing need identified for the new Local Plan. The Authority should note that paragraph 69 of the NPPF advises against the concentration of growth as proposed within Strategy Option 3, instead recommending that development plans should seek to accommodate at least 10% of their housing requirement on sites no larger than one hectare. Given the uplift in housing delivery which will be required to meet housing need, it would be prudent that the Council also consider the allocation of small and
medium sized sites, such as the promoted land at Lower Wyburns Farm, which can contribute directly to the next 5 year supply and be delivered quickly, making a more
immediate contribution to housing supply alongside this Strategy.
Strategy Option 4: Balanced Combination
2.6. Strategy Option 4 advances a balanced combination of the various Strategy Options presented, including making the best use of urban capacity (Option 1), building on one or two large growth areas (Option 3), and a number of smaller urban extensions (Option 2).
Claremont Planning strongly recommend that the Authority pursue the blended approach promoted within Option 4. It is considered that Option 4 represents the most sustainable means of meeting the District’s housing requirement, by maximising sites available within the existing urban area, and delivering smaller urban extensions at sustainable locations in accordance with the proposed settlement hierarchy. Paragraph 69 of the NPPF establishes that a blended approach which allocates small, medium, and larger sites for development is advisable, ensuring that any potential delays in the delivery of larger allocations do not
adversely affect housing delivery in the District.
2.7. Paragraph 35 of the NPPF sets out the tests for ‘soundness’ of development plans, establishing that plans should, as a minimum, seek to meet their areas objectively assessed housing need and be informed by agreements with other authorities so that any unmet need from neighbouring areas can be accommodated where it is practical to do so. The southern and northern parcels of the land promoted by Southern and Regional
Developments at Lower Wyburns Farm have been recognised by the Council within their Site Assessment Paper 2021, with references CFS068 and CFS069 respectively; for their potential to deliver growth through Option 2, small urban extensions. Claremont Planning
strongly support the Council’s recognition of the land’s potential and note that the land occupies a highly sustainable location adjacent to the District’s only Tier 1 settlement.
Furthermore, the promoted site should be recognised as a suitable location which could contribute towards unmet need arising from neighbouring authorities due to its close geographical proximity to adjacent districts, particularly to the Castle Point Borough and
Southend-on-Sea Districts, whilst also benefitting from a close functional relationship these due to its proximity to the strategic highway network, namely the A127.

3. Spatial Themes
Q9. Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and
coastal change wherever possible? How can we best protect current and future communities from flood risk and coastal change?

3.1. National policy, chiefly paragraph 161 of the NPPF, is clear in its expectations that development plans apply a sequential, risk-based approach to the location of development which includes taking into account all sources of flood risk as well as current and future
impacts of climate change. As such, it is agreed that a sequential approach to flood risk and coastal change should be adopted by the Plan, and this would be a sound approach that is consistent with national planning policy. As recognised by the Council, much of the
District is affected by Flood Zone 3 with flood risk likely to be subject to coastal change as a result of climate change. As such, it is recommended that development opportunities within areas at lower risk of flooding are fully considered by the Authority. Approaching flood risk and coastal change sequentially would also accord with the proposed settlement hierarchy, concentrating development at the main settlements of the District, including Rayleigh which are the areas within the District at lower risk of flooding.
3.2. The land at Lower Wyburns Farm, Daws Heath Road represents one such suitable location for development if the sequential approach to flood risk is adopted. With respect to the parcel of land south of Daws Heath Road, only a very small area along Daws Heath Road, is affected by Flood Zone 2. With respect to the promoted parcel of land north of the road, this is more heavily influenced by flood risk, being completely covered by Flood Zones 2 and 3. Previous representations submitted to the Council through the SHLAA/Call for Sites process by Claremont Planning have considered the flood risk present on the site at length and it is advanced that the flood zone 3 areas should be removed from consideration for development and instead contribute toward public open space provision and ecological enhancement measures. Any development on the northern parcel should be focused upon redeveloping the existing dwelling on the site, away from the flood prone
areas and towards the frontage with Daws Heath Road.
3.3. When assessing the flood risk of the promoted land at Lower Wyburns Farm within their initial site assessments, the Council also recognise that the majority of the promoted land is at low risk of flooding, scoring the northern and southern parcels of the site as 3 and 4 respectively for flood risk on a scale on for which 5 represents the best performing sites.
Given that the vast majority of the promoted land at Lower Wyburns Farm south of Daws Heath Road is located within Flood Zone 1, and the Council’s recognition that the site performs strongly in respect of flood risk; Claremont Planning consider that the
development of this land would be in accordance with the recommended sequential approach to flood risk in the Plan.

4. Housing for All
Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes, and tenures of housing?

4.1. Meeting the need for different types, sizes, and tenures of housing by requiring a suitable or negotiable mix of housing that is responsive to the type and location of development, as promoted by Option 2, is recommended by Claremont Planning. It is considered that this represents the most pragmatic approach to meeting these needs by providing flexibility in the market to ensure that the right types of homes are delivered in the right locations. Applying a blanket housing mix policy would fail to recognise that some types of land are
more well suited to certain forms of development. For example, both the Housing Topic Paper 2021 and 2017 SHMA establish that there is the greatest need for small and midsized semi-detached and detached dwellings. Claremont Planning consider that the release of Green Belt land, including the site at Lower Wyburns Farm should be strongly considered by the Council whereby the release of this land will both assist the Council in
meeting their overall housing need and facilitate the delivery of an appropriate mix of housing. In particular this will assist delivery of family sized housing which is better suited to delivery on greenfield land than constrained urban sites.

5. Green and Blue Infrastructure
Q32. With reference to the options above, or your own options, how do you feel we can best deliver quality green and blue infrastructure network throughout the Plan?
5.1. The Green and Blue Infrastructure Topic Paper 2021 identifies that previous housing and economic growth throughout South Essex has not been sufficient to meet the region’s growth potential. As such, Claremont Planning maintain that although delivering quality
green and blue infrastructure is valuable, this must be balanced against the region’s need for growth. It is therefore recommended that identifying general objectives for strategic green and blue infrastructure through the plan (Option 2) is pursued by the Authority, with this Option relying on other existing allocations, such as open space, local green space, and local wildlife site designations to deliver improvements. The suggestion identified within the Topic Paper that the Plan could still contain policies that help to deliver improvements to green and blue infrastructure, including the capture of funding through planning obligations associated with development is recommended to be advanced
alongside this approach. Advancing Option 2 would continue to promote the delivery of improvements on site where appropriate, without constraining the ability of development to make the most effective use on land by requiring on-site improvements to be delivered.
Moreover, it is not considered that detailed, site-specific policies are relevant for inclusion within a strategic plan of this nature where national planning policy establishes in Chapter 3 of the NPPF the role that strategic policies should play, which is to set the overall strategies for the pattern, scale and design quality of places. As such, policies relating to site specific provision of green and blue infrastructure would be more appropriately dealt
with through the preparation non-strategic level Plans and Policies such as those in Neighbourhood Plans.
5.2. The Green and Blue Infrastructure Topic Paper 2021 also establishes that the connectivity of green and blue infrastructure is challenging, with many poor green and blue linkages between towns, villages, rural areas and waterfronts. Whilst Option 3, requiring certain new
developments to provide local green and blue infrastructure on-site, may increase the quantum of green and blue infrastructure throughout Rochford, there is risk that this may worsen the connectivity of these spaces through their piecemeal development.
Contrastingly, securing funding through planning obligations as part of Option 2 could deliver strategic improvements to this network to be made in accordance with a wider vision for the area. This would represent a more effective and deliverable strategy, meeting that criteria for soundness as identified in the NPPF.

6. Town Centres and Retail
Q46. With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley?
How can we also ensure our village and neighbourhood centres remain vibrant?
6.1. Claremont Planning support the ambition of Options 5 and 10 in their recognition that delivering a suitable mix of uses including residential development is essential in
continuing to support the vitality and viability of town centres. It is considered important however, that the Council recognise the importance of allowing settlements to expand through new development outside of the existing settlement boundary, as this can allow the population of settlements to grow. This in turn can increase footfall to existing shops and services, and enhance the vitality and viability of these settlements, especially where good pedestrian connectivity to the town centre is present. Whilst it is recognised that the
consultation document identifies that town centres within the District have not suffered declines in footfall as acutely as national trends would indicate, further development and growth at a settlement could ensure that town centres remain sustainable in the future.

7. Green Belt and Rural Issues – Plan Objective 20 (p.69-70)
7.1. The recognition that the release of Green Belt land will be required to meet housing needs through the emerging Plan is strongly supported. It is agreed that the Council can demonstrate the exceptional circumstances necessary to justify this release, in accordance with paragraph 141 of the NPPF. The Consultation Document has sought to establish that a spatial strategy reliant on urban intensification will not deliver sufficient housing to meet the Council’s objectively assessed need and confirms that early discussions with adjacent authorities has not identified capacity for accommodating unmet need arising from Rochford. As such, it is agreed and supported that the emerging Local Plan will be able to
demonstrate the exceptional circumstances necessary to justify the release of Green Belt land.
7.2. The Rochford District and Southend-on-Sea Joint Green Belt Study (February 2020) forming the evidence base to this consultation contains detailed site assessments that identify the contribution made by promoted sites to the purposes of the Green Belt. Within
this report, the land at Lower Wyburns Farm was assessed as making a strong contribution to the purposes of the Green Belt, finding that the site presents a strong openness and has a closer relationship with the surrounding countryside than the urban area. Likewise, the initial assessment proformas prepared by the Authority also rated the identified site as relatively strongly performing Green Belt. These conclusions are refuted and it is considered that these assessments failed to recognise several key features of the promoted land which diminish its contribution to the Green Belt. Notably, assessments of the land around the site have failed to identify that both the north and south parcels of the site are currently in use and developed; with the original farmhouse and livery stables in the southern parcel alongside a range of buildings and yards that accommodate B2 Industrial uses with external storage areas and further Sui Generis horticultural and
residential uses located within the northern parcel. As such, a large quantum of the promoted site’s area represents previously developed land and should be prioritised for development.
7.3. The Joint Green Belt Study however establishes that the environmental and sustainability effects of development need to be considered when releasing land from the Green Belt, where it may be that the most sustainable locations for development may not be
appropriate or sustainable, with this pragmatic approach to Green Belt release strongly supported by Claremont Planning where it accords with the provisions of paragraph 142 of the NPPF. Specifically, paragraph 142 of the Framework recommends that plans should give first consideration to land which is previously developed and/or well served by public transport when considering Green Belt release. It has been established that a proportion of the land promoted by Southern and Regional Developments at Lower Wyburns Farm
represents previously developed land, as previously recognised in the Council’s 2017 SHELAA assessment of the southern parcel (CFS068), with built form existing on the southern parcel of the site in particular with a variety of B2 industrial sheds alongside an established concrete hardstanding and occupied by structures extending up to two stories in height, obscuring any view of the wider countryside and significantly reducing the land’s openness. Moreover, the industrial units occupying the land at present host a variety of established uses, including a lawn mower repair shop and vehicle servicing, alongside a camping and caravan site, whilst the northern parcel of land is used as a plant nursery. As
such, both parcels benefit from established activity and transport movements further reducing openness characteristics attributed to the site.
7.4. At present the Green Belt Study does not adequately consider the characteristics of the site with respect to its established uses, built form and recognitions as previously developed land. This is demonstrated through the Parcel Assessments included in the Green Belt Study, with the promoted land included incorrectly within Parcel 21 alongside undeveloped farmland. The parcel sizes identified through the study vary considerably in
shape and size, with specific characteristics of land informing the parcel sizes. An example of this and the resulting assessment of Green Belt factors is Parcel P29 that covers the land off Rayleigh Down Road and The Drive, where residential buildings and area of external caravan storage alongside/ horticultural/agricultural buildings have been recognised within a smaller parcel area and assessed as having less contribution to
Green Belt as a result. This approach of applying a smaller parcel should also have been identifeid for the land at Lower Wyburns Farm, which would have enabled its assessment separately from the woodland, playing fields and pasture that makes up the rest of parcel
21 to the east. The Green Belt Study undertaken has therefore not allowed for the appropriate assessment of edge of settlement sites that would otherwise be considered as sustainable allocation options and be taken forward for further consideration through the
Local Plan process.
7.5. The reduced openness and lack of rural character afforded by the existing structures on site reduces the land’s contribution to the Green Belt considerably. In accordance with the principles established by the Joint Green Belt Study, alongside the reduced contribution of
the land to the purposes of the Green Belt, the highly sustainable location of the site adjacent to Rayleigh and the accessibility of local services and facilities from the site, should also ensure that the land at Lower Wyburns Farm is identified as a suitable candidate for Green Belt release.

Q56b. With reference to Figure 44 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses?
How could that improve the completeness of Rayleigh?
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community Infrastructure [open space, education, healthcare, allotments, other]
4. Other

8.2. Promoted sites CFS068 and CFS069 (Land at Lower Wyburns Farm) identified on Figure 44 should be made available for residential development. Although land at Lower Wyburns Farm promoted by Southern and Regional Developments is not identified on the walking completeness score map presented within the ‘Complete Communities’ Topic Paper, the site is located adjacent to areas afforded attributed a walking completeness score of 8-10 showing that reasonable levels of services and facilities are located within the ‘walking catchment’ of the land. Notwithstanding this, it is recommended that the
Council be pragmatic in applying walking completeness scores where the Topic Paper confirms that being located outside of the comfortable walking catchment for a specific facility does not mean that the facility is inaccessible. This assertion is particularly relevant
for Rayleigh, where the Topic Paper establishes that 56% of the settlement is located within the walking catchment of a frequent bus service. A review of the promoted land’s context confirms that the site is located within a 5 minute walk from existing bus stops sited along the Eastwood Road. These bus stops provide very frequent services to a range of destinations including, Southend-on-Sea, Shoeburyness, Rayleigh, and Basildon Town
Centre. As such, Claremont Planning recommend that the Council recognises the highly sustainable location of the promoted land at Lower Wyburns Farm for residential
development, given both the variety of services and facilities located within the land’s walking catchment, and the site’s close proximity to frequent public transport services.
8.3. Moreover, the vision for Rayleigh advanced by the Consultation Document sets out the ambition to provide for a diverse range of housing which meet the needs of all in the community. The 2017 Strategic Housing Market Assessment (SHMA) establishes that both within Rochford, and across the South Essex region, the greatest additional demand for housing will be generated by households requiring family housing with three bedrooms. As such, it is considered that the release of the land at Lower Wyburns Farm from the Green Belt, and its allocation for residential development can strongly contribute to delivering housing to meet this need where greenfield land is considered to be more appropriate for
the delivery of family-sized housing. It is also advised that the Authority acknowledge the strategic location of the land at Lower Wyburns Farm in close proximity to the District boundary and connection to the A127 as a location which may be appropriate to meet any unmet need for family housing arising from the wider South Essex region.
8.4. It has been established that Rayleigh benefits from high levels of completeness, with a large percentage of the settlement located within the walking catchment of education, sport, leisure, and health facilities however, the ‘Complete Communities Topic Paper’ identifies that only 18% of Rayleigh is located within the walking catchment of green infrastructure. Previous representations made to the Authority promoting the land at Lower Wyburns Farm have identified that the site’s development will include provision of an area of public open space to the north west of the site. As such, it is considered that the allocation of the site will both continue to ensure that development at Rayleigh is located in the most sustainable locations, that are areas within the walking catchment of a good range of services and facilities, whilst also seeking to address deficiencies in green infrastructure provision in Rayleigh.
Enclosed: Site Location Plan: Lower Wyburns Farm, Daws Heath Road, Rayleigh
:Dwg SK001 Illustrative Masterplan

ROCHFORD NEW LOCAL PLAN: SPATIAL OPTIONS CONSULTATION- SUBMISSION OF REPRESENTATIONS ON BEHALF OF SOUTHERN & REGIONAL DEVELOPMENTS LIMITED
Claremont Planning Consultancy have been instructed by Southern and Regional Developments Limited to prepare and submit representations to the new Local Plan: Spatial Options consultation.
Southern and Regional Developments are in control of two sites within the Rochford District; the land at Lower Wyburns Farm, Rayleigh, and Sutton Road, Rochford, with both sites previously promoted to the Council through the 2018 Call for Sites exercise for the emerging
Local Plan. For clarity, it has therefore been considered prudent to prepare and submit representations to the Spatial Options consultation separately considering each site separately.
As such, please find the following sets of representations enclosed:
• Lower Wyburns Farm representations to Spatial Options- Location Plan and Illustrative
Masterplan enclosed.
• Sutton Road representations to Spatial Options - Location Plan enclosed
We trust that these representations are clear and will be duly taken into consideration, however, if Southern and Regional Developments or Claremont Planning can assist with providing any further information in relation to the sites at Lower Wyburns Farm and Sutton Road, or the content of the representations submitted, please do not hesitate to contact me on the details below.

Rochford District Council – Lower Wyburns Farm, Rayleigh
Representations to the Spatial Options
1. Introduction
1.1. On behalf of Southern and Regional Developments Ltd, Claremont Planning Consultancy has been instructed to prepare and submit representations to the Spatial Options consultation being undertaken by Rochford District Council to inform the emerging Local
Plan.

2. Strategy Options
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?

2.1. Claremont Planning, on behalf of Southern and Regional Development’s Ltd, are supportive of the settlement hierarchy proposed. The identification of Rayleigh as the only ‘Tier 1’ settlement within the District is supported, finding this proportionate to the settlement’s larger population and comprehensive service base, which is of both local and regional prominence. The proposed settlement hierarchy correctly recognises the strategic location of Rayleigh which affords the settlement a functional relationship with the adjacent
Southend, Basildon, Chelmsford, and London Districts.
2.2. It is recommended that the spatial strategy advanced by the emerging Local Plan be strongly informed by the proposed settlement hierarchy. The proposed hierarchy of settlements evidences that Rayleigh benefits from a wide range of retail, employment, and community facilities and therefore represents a highly sustainable location for development. In accordance with the provisions of Paragraph 16 of the National Planning
Policy Framework (NPPF), development plans should be prepared with the objective of contributing to the achievement of sustainable development. As such, it is advisable that the overall distribution of growth is informed by this imperative, and a larger quantum of
growth apportioned to those settlements which are identified by the hierarchy as being most sustainable, chiefly Rayleigh. To accommodate the necessary growth of Rayleigh a full review of the settlement boundary should be undertaken through this plan review process, with Green Belt release of suitable sites promoted to ensure that Rayleigh can accommodate the level of growth its position in the settlement hierarchy requires.

Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
Strategy Option 1: Urban Intensification
2.3. It is advised that Strategy Option 1: Urban Intensification is not advanced on its own. The current standard method identifies a housing requirement of 7,200 dwellings for the district across the next 20 years, however the consultation document establishes that only 4,500 new dwellings can be delivered through Option 1. Paragraph 35 of the NPPF identifies that Plans must provide a strategy which as a minimum seeks to meet the area’s objectively assessed needs in order to be found sound. Delivering development through Strategy Option 1 will result in a substantial shortfall in housing delivery and will unlikely be considered sound by the Inspector when the Plan is examined.
Strategy Option 2: Urban Extensions
2.4. It is recognised that Strategy Option 2, which seeks to spread development across several development sites of between 10 and 1,500 homes adjoining existing towns and villages, could deliver a sustainable distribution of housing growth. The dispersal of urban extensions based on the settlement hierarchy is supported, where this would see growth delivered at the most sustainable settlements in the District. In accordance with the proposed settlement hierarchy, the allocation of urban extensions at Rayleigh, the District’s largest and most sustainable settlement, should be prioritised if this option is taken forward. When considering urban extensions, they should not prohibit the appropriate review of a settlement’s boundary and site releases from the Green Belt for development elsewhere. Co-ordinating urban extensions that are typically large scale developments
alongside smaller site allocations will facilitate the delivery of small to medium sites as advised by the NPPF at Paragraph 69; which will enable the continual supply of housing through a maintained trajectory.
Strategy Option 3: Concentrated Growth
2.5. Concentrating growth in one or more locations of 1,500+ dwellings, as promoted within Strategy Option 3 is not supported on its own at this time. Large allocations and the development of new settlements, by virtue of their complexity and infrastructure requirements, have much longer lead in times for delivery and therefore would be likely to contribute towards meeting housing needs towards the end of the Plan period and beyond.
As such, pursuit of this Strategy Option alone will not deliver sufficient housing to meet the Authority’s housing needs in the earlier years of the Plan, leaving the Authority vulnerable to speculative development which is not Plan lead particularly if delays in the delivery of
these allocations arise. Topic Paper 9: Housing prepared in support of the Spatial Options Consultation 2021 illustrates that over the last 10 years Rochford’s historic rate of housing delivery is 227 dwellings per annum, requiring an uplift of around 60% in annual housing
completions to meet the local housing need identified for the new Local Plan. The Authority should note that paragraph 69 of the NPPF advises against the concentration of growth as proposed within Strategy Option 3, instead recommending that development plans should seek to accommodate at least 10% of their housing requirement on sites no larger than one hectare. Given the uplift in housing delivery which will be required to meet housing need, it would be prudent that the Council also consider the allocation of small and
medium sized sites, such as the promoted land at Lower Wyburns Farm, which can contribute directly to the next 5 year supply and be delivered quickly, making a more
immediate contribution to housing supply alongside this Strategy.
Strategy Option 4: Balanced Combination
2.6. Strategy Option 4 advances a balanced combination of the various Strategy Options presented, including making the best use of urban capacity (Option 1), building on one or two large growth areas (Option 3), and a number of smaller urban extensions (Option 2).
Claremont Planning strongly recommend that the Authority pursue the blended approach promoted within Option 4. It is considered that Option 4 represents the most sustainable means of meeting the District’s housing requirement, by maximising sites available within the existing urban area, and delivering smaller urban extensions at sustainable locations in accordance with the proposed settlement hierarchy. Paragraph 69 of the NPPF establishes that a blended approach which allocates small, medium, and larger sites for development is advisable, ensuring that any potential delays in the delivery of larger allocations do not
adversely affect housing delivery in the District.
2.7. Paragraph 35 of the NPPF sets out the tests for ‘soundness’ of development plans, establishing that plans should, as a minimum, seek to meet their areas objectively assessed housing need and be informed by agreements with other authorities so that any unmet need from neighbouring areas can be accommodated where it is practical to do so. The southern and northern parcels of the land promoted by Southern and Regional
Developments at Lower Wyburns Farm have been recognised by the Council within their Site Assessment Paper 2021, with references CFS068 and CFS069 respectively; for their potential to deliver growth through Option 2, small urban extensions. Claremont Planning
strongly support the Council’s recognition of the land’s potential and note that the land occupies a highly sustainable location adjacent to the District’s only Tier 1 settlement.
Furthermore, the promoted site should be recognised as a suitable location which could contribute towards unmet need arising from neighbouring authorities due to its close geographical proximity to adjacent districts, particularly to the Castle Point Borough and
Southend-on-Sea Districts, whilst also benefitting from a close functional relationship these due to its proximity to the strategic highway network, namely the A127.

3. Spatial Themes
Q9. Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and
coastal change wherever possible? How can we best protect current and future communities from flood risk and coastal change?

3.1. National policy, chiefly paragraph 161 of the NPPF, is clear in its expectations that development plans apply a sequential, risk-based approach to the location of development which includes taking into account all sources of flood risk as well as current and future
impacts of climate change. As such, it is agreed that a sequential approach to flood risk and coastal change should be adopted by the Plan, and this would be a sound approach that is consistent with national planning policy. As recognised by the Council, much of the
District is affected by Flood Zone 3 with flood risk likely to be subject to coastal change as a result of climate change. As such, it is recommended that development opportunities within areas at lower risk of flooding are fully considered by the Authority. Approaching flood risk and coastal change sequentially would also accord with the proposed settlement hierarchy, concentrating development at the main settlements of the District, including Rayleigh which are the areas within the District at lower risk of flooding.
3.2. The land at Lower Wyburns Farm, Daws Heath Road represents one such suitable location for development if the sequential approach to flood risk is adopted. With respect to the parcel of land south of Daws Heath Road, only a very small area along Daws Heath Road, is affected by Flood Zone 2. With respect to the promoted parcel of land north of the road, this is more heavily influenced by flood risk, being completely covered by Flood Zones 2 and 3. Previous representations submitted to the Council through the SHLAA/Call for Sites process by Claremont Planning have considered the flood risk present on the site at length and it is advanced that the flood zone 3 areas should be removed from consideration for development and instead contribute toward public open space provision and ecological enhancement measures. Any development on the northern parcel should be focused upon redeveloping the existing dwelling on the site, away from the flood prone
areas and towards the frontage with Daws Heath Road.
3.3. When assessing the flood risk of the promoted land at Lower Wyburns Farm within their initial site assessments, the Council also recognise that the majority of the promoted land is at low risk of flooding, scoring the northern and southern parcels of the site as 3 and 4 respectively for flood risk on a scale on for which 5 represents the best performing sites.
Given that the vast majority of the promoted land at Lower Wyburns Farm south of Daws Heath Road is located within Flood Zone 1, and the Council’s recognition that the site performs strongly in respect of flood risk; Claremont Planning consider that the
development of this land would be in accordance with the recommended sequential approach to flood risk in the Plan.

4. Housing for All
Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes, and tenures of housing?

4.1. Meeting the need for different types, sizes, and tenures of housing by requiring a suitable or negotiable mix of housing that is responsive to the type and location of development, as promoted by Option 2, is recommended by Claremont Planning. It is considered that this represents the most pragmatic approach to meeting these needs by providing flexibility in the market to ensure that the right types of homes are delivered in the right locations. Applying a blanket housing mix policy would fail to recognise that some types of land are
more well suited to certain forms of development. For example, both the Housing Topic Paper 2021 and 2017 SHMA establish that there is the greatest need for small and midsized semi-detached and detached dwellings. Claremont Planning consider that the release of Green Belt land, including the site at Lower Wyburns Farm should be strongly considered by the Council whereby the release of this land will both assist the Council in
meeting their overall housing need and facilitate the delivery of an appropriate mix of housing. In particular this will assist delivery of family sized housing which is better suited to delivery on greenfield land than constrained urban sites.

5. Green and Blue Infrastructure
Q32. With reference to the options above, or your own options, how do you feel we can best deliver quality green and blue infrastructure network throughout the Plan?
5.1. The Green and Blue Infrastructure Topic Paper 2021 identifies that previous housing and economic growth throughout South Essex has not been sufficient to meet the region’s growth potential. As such, Claremont Planning maintain that although delivering quality
green and blue infrastructure is valuable, this must be balanced against the region’s need for growth. It is therefore recommended that identifying general objectives for strategic green and blue infrastructure through the plan (Option 2) is pursued by the Authority, with this Option relying on other existing allocations, such as open space, local green space, and local wildlife site designations to deliver improvements. The suggestion identified within the Topic Paper that the Plan could still contain policies that help to deliver improvements to green and blue infrastructure, including the capture of funding through planning obligations associated with development is recommended to be advanced
alongside this approach. Advancing Option 2 would continue to promote the delivery of improvements on site where appropriate, without constraining the ability of development to make the most effective use on land by requiring on-site improvements to be delivered.
Moreover, it is not considered that detailed, site-specific policies are relevant for inclusion within a strategic plan of this nature where national planning policy establishes in Chapter 3 of the NPPF the role that strategic policies should play, which is to set the overall strategies for the pattern, scale and design quality of places. As such, policies relating to site specific provision of green and blue infrastructure would be more appropriately dealt
with through the preparation non-strategic level Plans and Policies such as those in Neighbourhood Plans.
5.2. The Green and Blue Infrastructure Topic Paper 2021 also establishes that the connectivity of green and blue infrastructure is challenging, with many poor green and blue linkages between towns, villages, rural areas and waterfronts. Whilst Option 3, requiring certain new
developments to provide local green and blue infrastructure on-site, may increase the quantum of green and blue infrastructure throughout Rochford, there is risk that this may worsen the connectivity of these spaces through their piecemeal development.
Contrastingly, securing funding through planning obligations as part of Option 2 could deliver strategic improvements to this network to be made in accordance with a wider vision for the area. This would represent a more effective and deliverable strategy, meeting that criteria for soundness as identified in the NPPF.

6. Town Centres and Retail
Q46. With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley?
How can we also ensure our village and neighbourhood centres remain vibrant?
6.1. Claremont Planning support the ambition of Options 5 and 10 in their recognition that delivering a suitable mix of uses including residential development is essential in
continuing to support the vitality and viability of town centres. It is considered important however, that the Council recognise the importance of allowing settlements to expand through new development outside of the existing settlement boundary, as this can allow the population of settlements to grow. This in turn can increase footfall to existing shops and services, and enhance the vitality and viability of these settlements, especially where good pedestrian connectivity to the town centre is present. Whilst it is recognised that the
consultation document identifies that town centres within the District have not suffered declines in footfall as acutely as national trends would indicate, further development and growth at a settlement could ensure that town centres remain sustainable in the future.

7. Green Belt and Rural Issues – Plan Objective 20 (p.69-70)
7.1. The recognition that the release of Green Belt land will be required to meet housing needs through the emerging Plan is strongly supported. It is agreed that the Council can demonstrate the exceptional circumstances necessary to justify this release, in accordance with paragraph 141 of the NPPF. The Consultation Document has sought to establish that a spatial strategy reliant on urban intensification will not deliver sufficient housing to meet the Council’s objectively assessed need and confirms that early discussions with adjacent authorities has not identified capacity for accommodating unmet need arising from Rochford. As such, it is agreed and supported that the emerging Local Plan will be able to
demonstrate the exceptional circumstances necessary to justify the release of Green Belt land.
7.2. The Rochford District and Southend-on-Sea Joint Green Belt Study (February 2020) forming the evidence base to this consultation contains detailed site assessments that identify the contribution made by promoted sites to the purposes of the Green Belt. Within
this report, the land at Lower Wyburns Farm was assessed as making a strong contribution to the purposes of the Green Belt, finding that the site presents a strong openness and has a closer relationship with the surrounding countryside than the urban area. Likewise, the initial assessment proformas prepared by the Authority also rated the identified site as relatively strongly performing Green Belt. These conclusions are refuted and it is considered that these assessments failed to recognise several key features of the promoted land which diminish its contribution to the Green Belt. Notably, assessments of the land around the site have failed to identify that both the north and south parcels of the site are currently in use and developed; with the original farmhouse and livery stables in the southern parcel alongside a range of buildings and yards that accommodate B2 Industrial uses with external storage areas and further Sui Generis horticultural and
residential uses located within the northern parcel. As such, a large quantum of the promoted site’s area represents previously developed land and should be prioritised for development.
7.3. The Joint Green Belt Study however establishes that the environmental and sustainability effects of development need to be considered when releasing land from the Green Belt, where it may be that the most sustainable locations for development may not be
appropriate or sustainable, with this pragmatic approach to Green Belt release strongly supported by Claremont Planning where it accords with the provisions of paragraph 142 of the NPPF. Specifically, paragraph 142 of the Framework recommends that plans should give first consideration to land which is previously developed and/or well served by public transport when considering Green Belt release. It has been established that a proportion of the land promoted by Southern and Regional Developments at Lower Wyburns Farm
represents previously developed land, as previously recognised in the Council’s 2017 SHELAA assessment of the southern parcel (CFS068), with built form existing on the southern parcel of the site in particular with a variety of B2 industrial sheds alongside an established concrete hardstanding and occupied by structures extending up to two stories in height, obscuring any view of the wider countryside and significantly reducing the land’s openness. Moreover, the industrial units occupying the land at present host a variety of established uses, including a lawn mower repair shop and vehicle servicing, alongside a camping and caravan site, whilst the northern parcel of land is used as a plant nursery. As
such, both parcels benefit from established activity and transport movements further reducing openness characteristics attributed to the site.
7.4. At present the Green Belt Study does not adequately consider the characteristics of the site with respect to its established uses, built form and recognitions as previously developed land. This is demonstrated through the Parcel Assessments included in the Green Belt Study, with the promoted land included incorrectly within Parcel 21 alongside undeveloped farmland. The parcel sizes identified through the study vary considerably in
shape and size, with specific characteristics of land informing the parcel sizes. An example of this and the resulting assessment of Green Belt factors is Parcel P29 that covers the land off Rayleigh Down Road and The Drive, where residential buildings and area of external caravan storage alongside/ horticultural/agricultural buildings have been recognised within a smaller parcel area and assessed as having less contribution to
Green Belt as a result. This approach of applying a smaller parcel should also have been identifeid for the land at Lower Wyburns Farm, which would have enabled its assessment separately from the woodland, playing fields and pasture that makes up the rest of parcel
21 to the east. The Green Belt Study undertaken has therefore not allowed for the appropriate assessment of edge of settlement sites that would otherwise be considered as sustainable allocation options and be taken forward for further consideration through the
Local Plan process.
7.5. The reduced openness and lack of rural character afforded by the existing structures on site reduces the land’s contribution to the Green Belt considerably. In accordance with the principles established by the Joint Green Belt Study, alongside the reduced contribution of
the land to the purposes of the Green Belt, the highly sustainable location of the site adjacent to Rayleigh and the accessibility of local services and facilities from the site, should also ensure that the land at Lower Wyburns Farm is identified as a suitable candidate for Green Belt release.

Q56b. With reference to Figure 44 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses?
How could that improve the completeness of Rayleigh?
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community Infrastructure [open space, education, healthcare, allotments, other]
4. Other

8.2. Promoted sites CFS068 and CFS069 (Land at Lower Wyburns Farm) identified on Figure 44 should be made available for residential development. Although land at Lower Wyburns Farm promoted by Southern and Regional Developments is not identified on the walking completeness score map presented within the ‘Complete Communities’ Topic Paper, the site is located adjacent to areas afforded attributed a walking completeness score of 8-10 showing that reasonable levels of services and facilities are located within the ‘walking catchment’ of the land. Notwithstanding this, it is recommended that the
Council be pragmatic in applying walking completeness scores where the Topic Paper confirms that being located outside of the comfortable walking catchment for a specific facility does not mean that the facility is inaccessible. This assertion is particularly relevant
for Rayleigh, where the Topic Paper establishes that 56% of the settlement is located within the walking catchment of a frequent bus service. A review of the promoted land’s context confirms that the site is located within a 5 minute walk from existing bus stops sited along the Eastwood Road. These bus stops provide very frequent services to a range of destinations including, Southend-on-Sea, Shoeburyness, Rayleigh, and Basildon Town
Centre. As such, Claremont Planning recommend that the Council recognises the highly sustainable location of the promoted land at Lower Wyburns Farm for residential
development, given both the variety of services and facilities located within the land’s walking catchment, and the site’s close proximity to frequent public transport services.
8.3. Moreover, the vision for Rayleigh advanced by the Consultation Document sets out the ambition to provide for a diverse range of housing which meet the needs of all in the community. The 2017 Strategic Housing Market Assessment (SHMA) establishes that both within Rochford, and across the South Essex region, the greatest additional demand for housing will be generated by households requiring family housing with three bedrooms. As such, it is considered that the release of the land at Lower Wyburns Farm from the Green Belt, and its allocation for residential development can strongly contribute to delivering housing to meet this need where greenfield land is considered to be more appropriate for
the delivery of family-sized housing. It is also advised that the Authority acknowledge the strategic location of the land at Lower Wyburns Farm in close proximity to the District boundary and connection to the A127 as a location which may be appropriate to meet any unmet need for family housing arising from the wider South Essex region.
8.4. It has been established that Rayleigh benefits from high levels of completeness, with a large percentage of the settlement located within the walking catchment of education, sport, leisure, and health facilities however, the ‘Complete Communities Topic Paper’ identifies that only 18% of Rayleigh is located within the walking catchment of green infrastructure. Previous representations made to the Authority promoting the land at Lower Wyburns Farm have identified that the site’s development will include provision of an area of public open space to the north west of the site. As such, it is considered that the allocation of the site will both continue to ensure that development at Rayleigh is located in the most sustainable locations, that are areas within the walking catchment of a good range of services and facilities, whilst also seeking to address deficiencies in green infrastructure provision in Rayleigh.
Enclosed: Site Location Plan: Lower Wyburns Farm, Daws Heath Road, Rayleigh
:Dwg SK001 Illustrative Masterplan

ROCHFORD NEW LOCAL PLAN: SPATIAL OPTIONS CONSULTATION- SUBMISSION OF REPRESENTATIONS ON BEHALF OF SOUTHERN & REGIONAL DEVELOPMENTS LIMITED
Claremont Planning Consultancy have been instructed by Southern and Regional Developments Limited to prepare and submit representations to the new Local Plan: Spatial Options consultation.
Southern and Regional Developments are in control of two sites within the Rochford District; the land at Lower Wyburns Farm, Rayleigh, and Sutton Road, Rochford, with both sites previously promoted to the Council through the 2018 Call for Sites exercise for the emerging
Local Plan. For clarity, it has therefore been considered prudent to prepare and submit representations to the Spatial Options consultation separately considering each site separately.
As such, please find the following sets of representations enclosed:
• Lower Wyburns Farm representations to Spatial Options- Location Plan and Illustrative
Masterplan enclosed.
• Sutton Road representations to Spatial Options - Location Plan enclosed
We trust that these representations are clear and will be duly taken into consideration, however, if Southern and Regional Developments or Claremont Planning can assist with providing any further information in relation to the sites at Lower Wyburns Farm and Sutton Road, or the content of the representations submitted, please do not hesitate to contact me on the details below.

Rochford District Council – Lower Wyburns Farm, Rayleigh
Representations to the Spatial Options
1. Introduction
1.1. On behalf of Southern and Regional Developments Ltd, Claremont Planning Consultancy has been instructed to prepare and submit representations to the Spatial Options consultation being undertaken by Rochford District Council to inform the emerging Local
Plan.

2. Strategy Options
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?

2.1. Claremont Planning, on behalf of Southern and Regional Development’s Ltd, are supportive of the settlement hierarchy proposed. The identification of Rayleigh as the only ‘Tier 1’ settlement within the District is supported, finding this proportionate to the settlement’s larger population and comprehensive service base, which is of both local and regional prominence. The proposed settlement hierarchy correctly recognises the strategic location of Rayleigh which affords the settlement a functional relationship with the adjacent
Southend, Basildon, Chelmsford, and London Districts.
2.2. It is recommended that the spatial strategy advanced by the emerging Local Plan be strongly informed by the proposed settlement hierarchy. The proposed hierarchy of settlements evidences that Rayleigh benefits from a wide range of retail, employment, and community facilities and therefore represents a highly sustainable location for development. In accordance with the provisions of Paragraph 16 of the National Planning
Policy Framework (NPPF), development plans should be prepared with the objective of contributing to the achievement of sustainable development. As such, it is advisable that the overall distribution of growth is informed by this imperative, and a larger quantum of
growth apportioned to those settlements which are identified by the hierarchy as being most sustainable, chiefly Rayleigh. To accommodate the necessary growth of Rayleigh a full review of the settlement boundary should be undertaken through this plan review process, with Green Belt release of suitable sites promoted to ensure that Rayleigh can accommodate the level of growth its position in the settlement hierarchy requires.

Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
Strategy Option 1: Urban Intensification
2.3. It is advised that Strategy Option 1: Urban Intensification is not advanced on its own. The current standard method identifies a housing requirement of 7,200 dwellings for the district across the next 20 years, however the consultation document establishes that only 4,500 new dwellings can be delivered through Option 1. Paragraph 35 of the NPPF identifies that Plans must provide a strategy which as a minimum seeks to meet the area’s objectively assessed needs in order to be found sound. Delivering development through Strategy Option 1 will result in a substantial shortfall in housing delivery and will unlikely be considered sound by the Inspector when the Plan is examined.
Strategy Option 2: Urban Extensions
2.4. It is recognised that Strategy Option 2, which seeks to spread development across several development sites of between 10 and 1,500 homes adjoining existing towns and villages, could deliver a sustainable distribution of housing growth. The dispersal of urban extensions based on the settlement hierarchy is supported, where this would see growth delivered at the most sustainable settlements in the District. In accordance with the proposed settlement hierarchy, the allocation of urban extensions at Rayleigh, the District’s largest and most sustainable settlement, should be prioritised if this option is taken forward. When considering urban extensions, they should not prohibit the appropriate review of a settlement’s boundary and site releases from the Green Belt for development elsewhere. Co-ordinating urban extensions that are typically large scale developments
alongside smaller site allocations will facilitate the delivery of small to medium sites as advised by the NPPF at Paragraph 69; which will enable the continual supply of housing through a maintained trajectory.
Strategy Option 3: Concentrated Growth
2.5. Concentrating growth in one or more locations of 1,500+ dwellings, as promoted within Strategy Option 3 is not supported on its own at this time. Large allocations and the development of new settlements, by virtue of their complexity and infrastructure requirements, have much longer lead in times for delivery and therefore would be likely to contribute towards meeting housing needs towards the end of the Plan period and beyond.
As such, pursuit of this Strategy Option alone will not deliver sufficient housing to meet the Authority’s housing needs in the earlier years of the Plan, leaving the Authority vulnerable to speculative development which is not Plan lead particularly if delays in the delivery of
these allocations arise. Topic Paper 9: Housing prepared in support of the Spatial Options Consultation 2021 illustrates that over the last 10 years Rochford’s historic rate of housing delivery is 227 dwellings per annum, requiring an uplift of around 60% in annual housing
completions to meet the local housing need identified for the new Local Plan. The Authority should note that paragraph 69 of the NPPF advises against the concentration of growth as proposed within Strategy Option 3, instead recommending that development plans should seek to accommodate at least 10% of their housing requirement on sites no larger than one hectare. Given the uplift in housing delivery which will be required to meet housing need, it would be prudent that the Council also consider the allocation of small and
medium sized sites, such as the promoted land at Lower Wyburns Farm, which can contribute directly to the next 5 year supply and be delivered quickly, making a more
immediate contribution to housing supply alongside this Strategy.
Strategy Option 4: Balanced Combination
2.6. Strategy Option 4 advances a balanced combination of the various Strategy Options presented, including making the best use of urban capacity (Option 1), building on one or two large growth areas (Option 3), and a number of smaller urban extensions (Option 2).
Claremont Planning strongly recommend that the Authority pursue the blended approach promoted within Option 4. It is considered that Option 4 represents the most sustainable means of meeting the District’s housing requirement, by maximising sites available within the existing urban area, and delivering smaller urban extensions at sustainable locations in accordance with the proposed settlement hierarchy. Paragraph 69 of the NPPF establishes that a blended approach which allocates small, medium, and larger sites for development is advisable, ensuring that any potential delays in the delivery of larger allocations do not
adversely affect housing delivery in the District.
2.7. Paragraph 35 of the NPPF sets out the tests for ‘soundness’ of development plans, establishing that plans should, as a minimum, seek to meet their areas objectively assessed housing need and be informed by agreements with other authorities so that any unmet need from neighbouring areas can be accommodated where it is practical to do so. The southern and northern parcels of the land promoted by Southern and Regional
Developments at Lower Wyburns Farm have been recognised by the Council within their Site Assessment Paper 2021, with references CFS068 and CFS069 respectively; for their potential to deliver growth through Option 2, small urban extensions. Claremont Planning
strongly support the Council’s recognition of the land’s potential and note that the land occupies a highly sustainable location adjacent to the District’s only Tier 1 settlement.
Furthermore, the promoted site should be recognised as a suitable location which could contribute towards unmet need arising from neighbouring authorities due to its close geographical proximity to adjacent districts, particularly to the Castle Point Borough and
Southend-on-Sea Districts, whilst also benefitting from a close functional relationship these due to its proximity to the strategic highway network, namely the A127.

3. Spatial Themes
Q9. Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and
coastal change wherever possible? How can we best protect current and future communities from flood risk and coastal change?

3.1. National policy, chiefly paragraph 161 of the NPPF, is clear in its expectations that development plans apply a sequential, risk-based approach to the location of development which includes taking into account all sources of flood risk as well as current and future
impacts of climate change. As such, it is agreed that a sequential approach to flood risk and coastal change should be adopted by the Plan, and this would be a sound approach that is consistent with national planning policy. As recognised by the Council, much of the
District is affected by Flood Zone 3 with flood risk likely to be subject to coastal change as a result of climate change. As such, it is recommended that development opportunities within areas at lower risk of flooding are fully considered by the Authority. Approaching flood risk and coastal change sequentially would also accord with the proposed settlement hierarchy, concentrating development at the main settlements of the District, including Rayleigh which are the areas within the District at lower risk of flooding.
3.2. The land at Lower Wyburns Farm, Daws Heath Road represents one such suitable location for development if the sequential approach to flood risk is adopted. With respect to the parcel of land south of Daws Heath Road, only a very small area along Daws Heath Road, is affected by Flood Zone 2. With respect to the promoted parcel of land north of the road, this is more heavily influenced by flood risk, being completely covered by Flood Zones 2 and 3. Previous representations submitted to the Council through the SHLAA/Call for Sites process by Claremont Planning have considered the flood risk present on the site at length and it is advanced that the flood zone 3 areas should be removed from consideration for development and instead contribute toward public open space provision and ecological enhancement measures. Any development on the northern parcel should be focused upon redeveloping the existing dwelling on the site, away from the flood prone
areas and towards the frontage with Daws Heath Road.
3.3. When assessing the flood risk of the promoted land at Lower Wyburns Farm within their initial site assessments, the Council also recognise that the majority of the promoted land is at low risk of flooding, scoring the northern and southern parcels of the site as 3 and 4 respectively for flood risk on a scale on for which 5 represents the best performing sites.
Given that the vast majority of the promoted land at Lower Wyburns Farm south of Daws Heath Road is located within Flood Zone 1, and the Council’s recognition that the site performs strongly in respect of flood risk; Claremont Planning consider that the
development of this land would be in accordance with the recommended sequential approach to flood risk in the Plan.

4. Housing for All
Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes, and tenures of housing?

4.1. Meeting the need for different types, sizes, and tenures of housing by requiring a suitable or negotiable mix of housing that is responsive to the type and location of development, as promoted by Option 2, is recommended by Claremont Planning. It is considered that this represents the most pragmatic approach to meeting these needs by providing flexibility in the market to ensure that the right types of homes are delivered in the right locations. Applying a blanket housing mix policy would fail to recognise that some types of land are
more well suited to certain forms of development. For example, both the Housing Topic Paper 2021 and 2017 SHMA establish that there is the greatest need for small and midsized semi-detached and detached dwellings. Claremont Planning consider that the release of Green Belt land, including the site at Lower Wyburns Farm should be strongly considered by the Council whereby the release of this land will both assist the Council in
meeting their overall housing need and facilitate the delivery of an appropriate mix of housing. In particular this will assist delivery of family sized housing which is better suited to delivery on greenfield land than constrained urban sites.

5. Green and Blue Infrastructure
Q32. With reference to the options above, or your own options, how do you feel we can best deliver quality green and blue infrastructure network throughout the Plan?
5.1. The Green and Blue Infrastructure Topic Paper 2021 identifies that previous housing and economic growth throughout South Essex has not been sufficient to meet the region’s growth potential. As such, Claremont Planning maintain that although delivering quality
green and blue infrastructure is valuable, this must be balanced against the region’s need for growth. It is therefore recommended that identifying general objectives for strategic green and blue infrastructure through the plan (Option 2) is pursued by the Authority, with this Option relying on other existing allocations, such as open space, local green space, and local wildlife site designations to deliver improvements. The suggestion identified within the Topic Paper that the Plan could still contain policies that help to deliver improvements to green and blue infrastructure, including the capture of funding through planning obligations associated with development is recommended to be advanced
alongside this approach. Advancing Option 2 would continue to promote the delivery of improvements on site where appropriate, without constraining the ability of development to make the most effective use on land by requiring on-site improvements to be delivered.
Moreover, it is not considered that detailed, site-specific policies are relevant for inclusion within a strategic plan of this nature where national planning policy establishes in Chapter 3 of the NPPF the role that strategic policies should play, which is to set the overall strategies for the pattern, scale and design quality of places. As such, policies relating to site specific provision of green and blue infrastructure would be more appropriately dealt
with through the preparation non-strategic level Plans and Policies such as those in Neighbourhood Plans.
5.2. The Green and Blue Infrastructure Topic Paper 2021 also establishes that the connectivity of green and blue infrastructure is challenging, with many poor green and blue linkages between towns, villages, rural areas and waterfronts. Whilst Option 3, requiring certain new
developments to provide local green and blue infrastructure on-site, may increase the quantum of green and blue infrastructure throughout Rochford, there is risk that this may worsen the connectivity of these spaces through their piecemeal development.
Contrastingly, securing funding through planning obligations as part of Option 2 could deliver strategic improvements to this network to be made in accordance with a wider vision for the area. This would represent a more effective and deliverable strategy, meeting that criteria for soundness as identified in the NPPF.

6. Town Centres and Retail
Q46. With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley?
How can we also ensure our village and neighbourhood centres remain vibrant?
6.1. Claremont Planning support the ambition of Options 5 and 10 in their recognition that delivering a suitable mix of uses including residential development is essential in
continuing to support the vitality and viability of town centres. It is considered important however, that the Council recognise the importance of allowing settlements to expand through new development outside of the existing settlement boundary, as this can allow the population of settlements to grow. This in turn can increase footfall to existing shops and services, and enhance the vitality and viability of these settlements, especially where good pedestrian connectivity to the town centre is present. Whilst it is recognised that the
consultation document identifies that town centres within the District have not suffered declines in footfall as acutely as national trends would indicate, further development and growth at a settlement could ensure that town centres remain sustainable in the future.

7. Green Belt and Rural Issues – Plan Objective 20 (p.69-70)
7.1. The recognition that the release of Green Belt land will be required to meet housing needs through the emerging Plan is strongly supported. It is agreed that the Council can demonstrate the exceptional circumstances necessary to justify this release, in accordance with paragraph 141 of the NPPF. The Consultation Document has sought to establish that a spatial strategy reliant on urban intensification will not deliver sufficient housing to meet the Council’s objectively assessed need and confirms that early discussions with adjacent authorities has not identified capacity for accommodating unmet need arising from Rochford. As such, it is agreed and supported that the emerging Local Plan will be able to
demonstrate the exceptional circumstances necessary to justify the release of Green Belt land.
7.2. The Rochford District and Southend-on-Sea Joint Green Belt Study (February 2020) forming the evidence base to this consultation contains detailed site assessments that identify the contribution made by promoted sites to the purposes of the Green Belt. Within
this report, the land at Lower Wyburns Farm was assessed as making a strong contribution to the purposes of the Green Belt, finding that the site presents a strong openness and has a closer relationship with the surrounding countryside than the urban area. Likewise, the initial assessment proformas prepared by the Authority also rated the identified site as relatively strongly performing Green Belt. These conclusions are refuted and it is considered that these assessments failed to recognise several key features of the promoted land which diminish its contribution to the Green Belt. Notably, assessments of the land around the site have failed to identify that both the north and south parcels of the site are currently in use and developed; with the original farmhouse and livery stables in the southern parcel alongside a range of buildings and yards that accommodate B2 Industrial uses with external storage areas and further Sui Generis horticultural and
residential uses located within the northern parcel. As such, a large quantum of the promoted site’s area represents previously developed land and should be prioritised for development.
7.3. The Joint Green Belt Study however establishes that the environmental and sustainability effects of development need to be considered when releasing land from the Green Belt, where it may be that the most sustainable locations for development may not be
appropriate or sustainable, with this pragmatic approach to Green Belt release strongly supported by Claremont Planning where it accords with the provisions of paragraph 142 of the NPPF. Specifically, paragraph 142 of the Framework recommends that plans should give first consideration to land which is previously developed and/or well served by public transport when considering Green Belt release. It has been established that a proportion of the land promoted by Southern and Regional Developments at Lower Wyburns Farm
represents previously developed land, as previously recognised in the Council’s 2017 SHELAA assessment of the southern parcel (CFS068), with built form existing on the southern parcel of the site in particular with a variety of B2 industrial sheds alongside an established concrete hardstanding and occupied by structures extending up to two stories in height, obscuring any view of the wider countryside and significantly reducing the land’s openness. Moreover, the industrial units occupying the land at present host a variety of established uses, including a lawn mower repair shop and vehicle servicing, alongside a camping and caravan site, whilst the northern parcel of land is used as a plant nursery. As
such, both parcels benefit from established activity and transport movements further reducing openness characteristics attributed to the site.
7.4. At present the Green Belt Study does not adequately consider the characteristics of the site with respect to its established uses, built form and recognitions as previously developed land. This is demonstrated through the Parcel Assessments included in the Green Belt Study, with the promoted land included incorrectly within Parcel 21 alongside undeveloped farmland. The parcel sizes identified through the study vary considerably in
shape and size, with specific characteristics of land informing the parcel sizes. An example of this and the resulting assessment of Green Belt factors is Parcel P29 that covers the land off Rayleigh Down Road and The Drive, where residential buildings and area of external caravan storage alongside/ horticultural/agricultural buildings have been recognised within a smaller parcel area and assessed as having less contribution to
Green Belt as a result. This approach of applying a smaller parcel should also have been identifeid for the land at Lower Wyburns Farm, which would have enabled its assessment separately from the woodland, playing fields and pasture that makes up the rest of parcel
21 to the east. The Green Belt Study undertaken has therefore not allowed for the appropriate assessment of edge of settlement sites that would otherwise be considered as sustainable allocation options and be taken forward for further consideration through the
Local Plan process.
7.5. The reduced openness and lack of rural character afforded by the existing structures on site reduces the land’s contribution to the Green Belt considerably. In accordance with the principles established by the Joint Green Belt Study, alongside the reduced contribution of
the land to the purposes of the Green Belt, the highly sustainable location of the site adjacent to Rayleigh and the accessibility of local services and facilities from the site, should also ensure that the land at Lower Wyburns Farm is identified as a suitable candidate for Green Belt release.

Q56b. With reference to Figure 44 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses?
How could that improve the completeness of Rayleigh?
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community Infrastructure [open space, education, healthcare, allotments, other]
4. Other

8.2. Promoted sites CFS068 and CFS069 (Land at Lower Wyburns Farm) identified on Figure 44 should be made available for residential development. Although land at Lower Wyburns Farm promoted by Southern and Regional Developments is not identified on the walking completeness score map presented within the ‘Complete Communities’ Topic Paper, the site is located adjacent to areas afforded attributed a walking completeness score of 8-10 showing that reasonable levels of services and facilities are located within the ‘walking catchment’ of the land. Notwithstanding this, it is recommended that the
Council be pragmatic in applying walking completeness scores where the Topic Paper confirms that being located outside of the comfortable walking catchment for a specific facility does not mean that the facility is inaccessible. This assertion is particularly relevant
for Rayleigh, where the Topic Paper establishes that 56% of the settlement is located within the walking catchment of a frequent bus service. A review of the promoted land’s context confirms that the site is located within a 5 minute walk from existing bus stops sited along the Eastwood Road. These bus stops provide very frequent services to a range of destinations including, Southend-on-Sea, Shoeburyness, Rayleigh, and Basildon Town
Centre. As such, Claremont Planning recommend that the Council recognises the highly sustainable location of the promoted land at Lower Wyburns Farm for residential
development, given both the variety of services and facilities located within the land’s walking catchment, and the site’s close proximity to frequent public transport services.
8.3. Moreover, the vision for Rayleigh advanced by the Consultation Document sets out the ambition to provide for a diverse range of housing which meet the needs of all in the community. The 2017 Strategic Housing Market Assessment (SHMA) establishes that both within Rochford, and across the South Essex region, the greatest additional demand for housing will be generated by households requiring family housing with three bedrooms. As such, it is considered that the release of the land at Lower Wyburns Farm from the Green Belt, and its allocation for residential development can strongly contribute to delivering housing to meet this need where greenfield land is considered to be more appropriate for
the delivery of family-sized housing. It is also advised that the Authority acknowledge the strategic location of the land at Lower Wyburns Farm in close proximity to the District boundary and connection to the A127 as a location which may be appropriate to meet any unmet need for family housing arising from the wider South Essex region.
8.4. It has been established that Rayleigh benefits from high levels of completeness, with a large percentage of the settlement located within the walking catchment of education, sport, leisure, and health facilities however, the ‘Complete Communities Topic Paper’ identifies that only 18% of Rayleigh is located within the walking catchment of green infrastructure. Previous representations made to the Authority promoting the land at Lower Wyburns Farm have identified that the site’s development will include provision of an area of public open space to the north west of the site. As such, it is considered that the allocation of the site will both continue to ensure that development at Rayleigh is located in the most sustainable locations, that are areas within the walking catchment of a good range of services and facilities, whilst also seeking to address deficiencies in green infrastructure provision in Rayleigh.
Enclosed: Site Location Plan: Lower Wyburns Farm, Daws Heath Road, Rayleigh
:Dwg SK001 Illustrative Masterplan

ROCHFORD NEW LOCAL PLAN: SPATIAL OPTIONS CONSULTATION- SUBMISSION OF REPRESENTATIONS ON BEHALF OF SOUTHERN & REGIONAL DEVELOPMENTS LIMITED
Claremont Planning Consultancy have been instructed by Southern and Regional Developments Limited to prepare and submit representations to the new Local Plan: Spatial Options consultation.
Southern and Regional Developments are in control of two sites within the Rochford District; the land at Lower Wyburns Farm, Rayleigh, and Sutton Road, Rochford, with both sites previously promoted to the Council through the 2018 Call for Sites exercise for the emerging
Local Plan. For clarity, it has therefore been considered prudent to prepare and submit representations to the Spatial Options consultation separately considering each site separately.
As such, please find the following sets of representations enclosed:
• Lower Wyburns Farm representations to Spatial Options- Location Plan and Illustrative
Masterplan enclosed.
• Sutton Road representations to Spatial Options - Location Plan enclosed
We trust that these representations are clear and will be duly taken into consideration, however, if Southern and Regional Developments or Claremont Planning can assist with providing any further information in relation to the sites at Lower Wyburns Farm and Sutton Road, or the content of the representations submitted, please do not hesitate to contact me on the details below.

Rochford District Council – Lower Wyburns Farm, Rayleigh
Representations to the Spatial Options
1. Introduction
1.1. On behalf of Southern and Regional Developments Ltd, Claremont Planning Consultancy has been instructed to prepare and submit representations to the Spatial Options consultation being undertaken by Rochford District Council to inform the emerging Local
Plan.

2. Strategy Options
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?

2.1. Claremont Planning, on behalf of Southern and Regional Development’s Ltd, are supportive of the settlement hierarchy proposed. The identification of Rayleigh as the only ‘Tier 1’ settlement within the District is supported, finding this proportionate to the settlement’s larger population and comprehensive service base, which is of both local and regional prominence. The proposed settlement hierarchy correctly recognises the strategic location of Rayleigh which affords the settlement a functional relationship with the adjacent
Southend, Basildon, Chelmsford, and London Districts.
2.2. It is recommended that the spatial strategy advanced by the emerging Local Plan be strongly informed by the proposed settlement hierarchy. The proposed hierarchy of settlements evidences that Rayleigh benefits from a wide range of retail, employment, and community facilities and therefore represents a highly sustainable location for development. In accordance with the provisions of Paragraph 16 of the National Planning
Policy Framework (NPPF), development plans should be prepared with the objective of contributing to the achievement of sustainable development. As such, it is advisable that the overall distribution of growth is informed by this imperative, and a larger quantum of
growth apportioned to those settlements which are identified by the hierarchy as being most sustainable, chiefly Rayleigh. To accommodate the necessary growth of Rayleigh a full review of the settlement boundary should be undertaken through this plan review process, with Green Belt release of suitable sites promoted to ensure that Rayleigh can accommodate the level of growth its position in the settlement hierarchy requires.

Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
Strategy Option 1: Urban Intensification
2.3. It is advised that Strategy Option 1: Urban Intensification is not advanced on its own. The current standard method identifies a housing requirement of 7,200 dwellings for the district across the next 20 years, however the consultation document establishes that only 4,500 new dwellings can be delivered through Option 1. Paragraph 35 of the NPPF identifies that Plans must provide a strategy which as a minimum seeks to meet the area’s objectively assessed needs in order to be found sound. Delivering development through Strategy Option 1 will result in a substantial shortfall in housing delivery and will unlikely be considered sound by the Inspector when the Plan is examined.
Strategy Option 2: Urban Extensions
2.4. It is recognised that Strategy Option 2, which seeks to spread development across several development sites of between 10 and 1,500 homes adjoining existing towns and villages, could deliver a sustainable distribution of housing growth. The dispersal of urban extensions based on the settlement hierarchy is supported, where this would see growth delivered at the most sustainable settlements in the District. In accordance with the proposed settlement hierarchy, the allocation of urban extensions at Rayleigh, the District’s largest and most sustainable settlement, should be prioritised if this option is taken forward. When considering urban extensions, they should not prohibit the appropriate review of a settlement’s boundary and site releases from the Green Belt for development elsewhere. Co-ordinating urban extensions that are typically large scale developments
alongside smaller site allocations will facilitate the delivery of small to medium sites as advised by the NPPF at Paragraph 69; which will enable the continual supply of housing through a maintained trajectory.
Strategy Option 3: Concentrated Growth
2.5. Concentrating growth in one or more locations of 1,500+ dwellings, as promoted within Strategy Option 3 is not supported on its own at this time. Large allocations and the development of new settlements, by virtue of their complexity and infrastructure requirements, have much longer lead in times for delivery and therefore would be likely to contribute towards meeting housing needs towards the end of the Plan period and beyond.
As such, pursuit of this Strategy Option alone will not deliver sufficient housing to meet the Authority’s housing needs in the earlier years of the Plan, leaving the Authority vulnerable to speculative development which is not Plan lead particularly if delays in the delivery of
these allocations arise. Topic Paper 9: Housing prepared in support of the Spatial Options Consultation 2021 illustrates that over the last 10 years Rochford’s historic rate of housing delivery is 227 dwellings per annum, requiring an uplift of around 60% in annual housing
completions to meet the local housing need identified for the new Local Plan. The Authority should note that paragraph 69 of the NPPF advises against the concentration of growth as proposed within Strategy Option 3, instead recommending that development plans should seek to accommodate at least 10% of their housing requirement on sites no larger than one hectare. Given the uplift in housing delivery which will be required to meet housing need, it would be prudent that the Council also consider the allocation of small and
medium sized sites, such as the promoted land at Lower Wyburns Farm, which can contribute directly to the next 5 year supply and be delivered quickly, making a more
immediate contribution to housing supply alongside this Strategy.
Strategy Option 4: Balanced Combination
2.6. Strategy Option 4 advances a balanced combination of the various Strategy Options presented, including making the best use of urban capacity (Option 1), building on one or two large growth areas (Option 3), and a number of smaller urban extensions (Option 2).
Claremont Planning strongly recommend that the Authority pursue the blended approach promoted within Option 4. It is considered that Option 4 represents the most sustainable means of meeting the District’s housing requirement, by maximising sites available within the existing urban area, and delivering smaller urban extensions at sustainable locations in accordance with the proposed settlement hierarchy. Paragraph 69 of the NPPF establishes that a blended approach which allocates small, medium, and larger sites for development is advisable, ensuring that any potential delays in the delivery of larger allocations do not
adversely affect housing delivery in the District.
2.7. Paragraph 35 of the NPPF sets out the tests for ‘soundness’ of development plans, establishing that plans should, as a minimum, seek to meet their areas objectively assessed housing need and be informed by agreements with other authorities so that any unmet need from neighbouring areas can be accommodated where it is practical to do so. The southern and northern parcels of the land promoted by Southern and Regional
Developments at Lower Wyburns Farm have been recognised by the Council within their Site Assessment Paper 2021, with references CFS068 and CFS069 respectively; for their potential to deliver growth through Option 2, small urban extensions. Claremont Planning
strongly support the Council’s recognition of the land’s potential and note that the land occupies a highly sustainable location adjacent to the District’s only Tier 1 settlement.
Furthermore, the promoted site should be recognised as a suitable location which could contribute towards unmet need arising from neighbouring authorities due to its close geographical proximity to adjacent districts, particularly to the Castle Point Borough and
Southend-on-Sea Districts, whilst also benefitting from a close functional relationship these due to its proximity to the strategic highway network, namely the A127.

3. Spatial Themes
Q9. Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and
coastal change wherever possible? How can we best protect current and future communities from flood risk and coastal change?

3.1. National policy, chiefly paragraph 161 of the NPPF, is clear in its expectations that development plans apply a sequential, risk-based approach to the location of development which includes taking into account all sources of flood risk as well as current and future
impacts of climate change. As such, it is agreed that a sequential approach to flood risk and coastal change should be adopted by the Plan, and this would be a sound approach that is consistent with national planning policy. As recognised by the Council, much of the
District is affected by Flood Zone 3 with flood risk likely to be subject to coastal change as a result of climate change. As such, it is recommended that development opportunities within areas at lower risk of flooding are fully considered by the Authority. Approaching flood risk and coastal change sequentially would also accord with the proposed settlement hierarchy, concentrating development at the main settlements of the District, including Rayleigh which are the areas within the District at lower risk of flooding.
3.2. The land at Lower Wyburns Farm, Daws Heath Road represents one such suitable location for development if the sequential approach to flood risk is adopted. With respect to the parcel of land south of Daws Heath Road, only a very small area along Daws Heath Road, is affected by Flood Zone 2. With respect to the promoted parcel of land north of the road, this is more heavily influenced by flood risk, being completely covered by Flood Zones 2 and 3. Previous representations submitted to the Council through the SHLAA/Call for Sites process by Claremont Planning have considered the flood risk present on the site at length and it is advanced that the flood zone 3 areas should be removed from consideration for development and instead contribute toward public open space provision and ecological enhancement measures. Any development on the northern parcel should be focused upon redeveloping the existing dwelling on the site, away from the flood prone
areas and towards the frontage with Daws Heath Road.
3.3. When assessing the flood risk of the promoted land at Lower Wyburns Farm within their initial site assessments, the Council also recognise that the majority of the promoted land is at low risk of flooding, scoring the northern and southern parcels of the site as 3 and 4 respectively for flood risk on a scale on for which 5 represents the best performing sites.
Given that the vast majority of the promoted land at Lower Wyburns Farm south of Daws Heath Road is located within Flood Zone 1, and the Council’s recognition that the site performs strongly in respect of flood risk; Claremont Planning consider that the
development of this land would be in accordance with the recommended sequential approach to flood risk in the Plan.

4. Housing for All
Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes, and tenures of housing?

4.1. Meeting the need for different types, sizes, and tenures of housing by requiring a suitable or negotiable mix of housing that is responsive to the type and location of development, as promoted by Option 2, is recommended by Claremont Planning. It is considered that this represents the most pragmatic approach to meeting these needs by providing flexibility in the market to ensure that the right types of homes are delivered in the right locations. Applying a blanket housing mix policy would fail to recognise that some types of land are
more well suited to certain forms of development. For example, both the Housing Topic Paper 2021 and 2017 SHMA establish that there is the greatest need for small and midsized semi-detached and detached dwellings. Claremont Planning consider that the release of Green Belt land, including the site at Lower Wyburns Farm should be strongly considered by the Council whereby the release of this land will both assist the Council in
meeting their overall housing need and facilitate the delivery of an appropriate mix of housing. In particular this will assist delivery of family sized housing which is better suited to delivery on greenfield land than constrained urban sites.

5. Green and Blue Infrastructure
Q32. With reference to the options above, or your own options, how do you feel we can best deliver quality green and blue infrastructure network throughout the Plan?
5.1. The Green and Blue Infrastructure Topic Paper 2021 identifies that previous housing and economic growth throughout South Essex has not been sufficient to meet the region’s growth potential. As such, Claremont Planning maintain that although delivering quality
green and blue infrastructure is valuable, this must be balanced against the region’s need for growth. It is therefore recommended that identifying general objectives for strategic green and blue infrastructure through the plan (Option 2) is pursued by the Authority, with this Option relying on other existing allocations, such as open space, local green space, and local wildlife site designations to deliver improvements. The suggestion identified within the Topic Paper that the Plan could still contain policies that help to deliver improvements to green and blue infrastructure, including the capture of funding through planning obligations associated with development is recommended to be advanced
alongside this approach. Advancing Option 2 would continue to promote the delivery of improvements on site where appropriate, without constraining the ability of development to make the most effective use on land by requiring on-site improvements to be delivered.
Moreover, it is not considered that detailed, site-specific policies are relevant for inclusion within a strategic plan of this nature where national planning policy establishes in Chapter 3 of the NPPF the role that strategic policies should play, which is to set the overall strategies for the pattern, scale and design quality of places. As such, policies relating to site specific provision of green and blue infrastructure would be more appropriately dealt
with through the preparation non-strategic level Plans and Policies such as those in Neighbourhood Plans.
5.2. The Green and Blue Infrastructure Topic Paper 2021 also establishes that the connectivity of green and blue infrastructure is challenging, with many poor green and blue linkages between towns, villages, rural areas and waterfronts. Whilst Option 3, requiring certain new
developments to provide local green and blue infrastructure on-site, may increase the quantum of green and blue infrastructure throughout Rochford, there is risk that this may worsen the connectivity of these spaces through their piecemeal development.
Contrastingly, securing funding through planning obligations as part of Option 2 could deliver strategic improvements to this network to be made in accordance with a wider vision for the area. This would represent a more effective and deliverable strategy, meeting that criteria for soundness as identified in the NPPF.

6. Town Centres and Retail
Q46. With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley?
How can we also ensure our village and neighbourhood centres remain vibrant?
6.1. Claremont Planning support the ambition of Options 5 and 10 in their recognition that delivering a suitable mix of uses including residential development is essential in
continuing to support the vitality and viability of town centres. It is considered important however, that the Council recognise the importance of allowing settlements to expand through new development outside of the existing settlement boundary, as this can allow the population of settlements to grow. This in turn can increase footfall to existing shops and services, and enhance the vitality and viability of these settlements, especially where good pedestrian connectivity to the town centre is present. Whilst it is recognised that the
consultation document identifies that town centres within the District have not suffered declines in footfall as acutely as national trends would indicate, further development and growth at a settlement could ensure that town centres remain sustainable in the future.

7. Green Belt and Rural Issues – Plan Objective 20 (p.69-70)
7.1. The recognition that the release of Green Belt land will be required to meet housing needs through the emerging Plan is strongly supported. It is agreed that the Council can demonstrate the exceptional circumstances necessary to justify this release, in accordance with paragraph 141 of the NPPF. The Consultation Document has sought to establish that a spatial strategy reliant on urban intensification will not deliver sufficient housing to meet the Council’s objectively assessed need and confirms that early discussions with adjacent authorities has not identified capacity for accommodating unmet need arising from Rochford. As such, it is agreed and supported that the emerging Local Plan will be able to
demonstrate the exceptional circumstances necessary to justify the release of Green Belt land.
7.2. The Rochford District and Southend-on-Sea Joint Green Belt Study (February 2020) forming the evidence base to this consultation contains detailed site assessments that identify the contribution made by promoted sites to the purposes of the Green Belt. Within
this report, the land at Lower Wyburns Farm was assessed as making a strong contribution to the purposes of the Green Belt, finding that the site presents a strong openness and has a closer relationship with the surrounding countryside than the urban area. Likewise, the initial assessment proformas prepared by the Authority also rated the identified site as relatively strongly performing Green Belt. These conclusions are refuted and it is considered that these assessments failed to recognise several key features of the promoted land which diminish its contribution to the Green Belt. Notably, assessments of the land around the site have failed to identify that both the north and south parcels of the site are currently in use and developed; with the original farmhouse and livery stables in the southern parcel alongside a range of buildings and yards that accommodate B2 Industrial uses with external storage areas and further Sui Generis horticultural and
residential uses located within the northern parcel. As such, a large quantum of the promoted site’s area represents previously developed land and should be prioritised for development.
7.3. The Joint Green Belt Study however establishes that the environmental and sustainability effects of development need to be considered when releasing land from the Green Belt, where it may be that the most sustainable locations for development may not be
appropriate or sustainable, with this pragmatic approach to Green Belt release strongly supported by Claremont Planning where it accords with the provisions of paragraph 142 of the NPPF. Specifically, paragraph 142 of the Framework recommends that plans should give first consideration to land which is previously developed and/or well served by public transport when considering Green Belt release. It has been established that a proportion of the land promoted by Southern and Regional Developments at Lower Wyburns Farm
represents previously developed land, as previously recognised in the Council’s 2017 SHELAA assessment of the southern parcel (CFS068), with built form existing on the southern parcel of the site in particular with a variety of B2 industrial sheds alongside an established concrete hardstanding and occupied by structures extending up to two stories in height, obscuring any view of the wider countryside and significantly reducing the land’s openness. Moreover, the industrial units occupying the land at present host a variety of established uses, including a lawn mower repair shop and vehicle servicing, alongside a camping and caravan site, whilst the northern parcel of land is used as a plant nursery. As
such, both parcels benefit from established activity and transport movements further reducing openness characteristics attributed to the site.
7.4. At present the Green Belt Study does not adequately consider the characteristics of the site with respect to its established uses, built form and recognitions as previously developed land. This is demonstrated through the Parcel Assessments included in the Green Belt Study, with the promoted land included incorrectly within Parcel 21 alongside undeveloped farmland. The parcel sizes identified through the study vary considerably in
shape and size, with specific characteristics of land informing the parcel sizes. An example of this and the resulting assessment of Green Belt factors is Parcel P29 that covers the land off Rayleigh Down Road and The Drive, where residential buildings and area of external caravan storage alongside/ horticultural/agricultural buildings have been recognised within a smaller parcel area and assessed as having less contribution to
Green Belt as a result. This approach of applying a smaller parcel should also have been identifeid for the land at Lower Wyburns Farm, which would have enabled its assessment separately from the woodland, playing fields and pasture that makes up the rest of parcel
21 to the east. The Green Belt Study undertaken has therefore not allowed for the appropriate assessment of edge of settlement sites that would otherwise be considered as sustainable allocation options and be taken forward for further consideration through the
Local Plan process.
7.5. The reduced openness and lack of rural character afforded by the existing structures on site reduces the land’s contribution to the Green Belt considerably. In accordance with the principles established by the Joint Green Belt Study, alongside the reduced contribution of
the land to the purposes of the Green Belt, the highly sustainable location of the site adjacent to Rayleigh and the accessibility of local services and facilities from the site, should also ensure that the land at Lower Wyburns Farm is identified as a suitable candidate for Green Belt release.

Q56b. With reference to Figure 44 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses?
How could that improve the completeness of Rayleigh?
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community Infrastructure [open space, education, healthcare, allotments, other]
4. Other

8.2. Promoted sites CFS068 and CFS069 (Land at Lower Wyburns Farm) identified on Figure 44 should be made available for residential development. Although land at Lower Wyburns Farm promoted by Southern and Regional Developments is not identified on the walking completeness score map presented within the ‘Complete Communities’ Topic Paper, the site is located adjacent to areas afforded attributed a walking completeness score of 8-10 showing that reasonable levels of services and facilities are located within the ‘walking catchment’ of the land. Notwithstanding this, it is recommended that the
Council be pragmatic in applying walking completeness scores where the Topic Paper confirms that being located outside of the comfortable walking catchment for a specific facility does not mean that the facility is inaccessible. This assertion is particularly relevant
for Rayleigh, where the Topic Paper establishes that 56% of the settlement is located within the walking catchment of a frequent bus service. A review of the promoted land’s context confirms that the site is located within a 5 minute walk from existing bus stops sited along the Eastwood Road. These bus stops provide very frequent services to a range of destinations including, Southend-on-Sea, Shoeburyness, Rayleigh, and Basildon Town
Centre. As such, Claremont Planning recommend that the Council recognises the highly sustainable location of the promoted land at Lower Wyburns Farm for residential
development, given both the variety of services and facilities located within the land’s walking catchment, and the site’s close proximity to frequent public transport services.
8.3. Moreover, the vision for Rayleigh advanced by the Consultation Document sets out the ambition to provide for a diverse range of housing which meet the needs of all in the community. The 2017 Strategic Housing Market Assessment (SHMA) establishes that both within Rochford, and across the South Essex region, the greatest additional demand for housing will be generated by households requiring family housing with three bedrooms. As such, it is considered that the release of the land at Lower Wyburns Farm from the Green Belt, and its allocation for residential development can strongly contribute to delivering housing to meet this need where greenfield land is considered to be more appropriate for
the delivery of family-sized housing. It is also advised that the Authority acknowledge the strategic location of the land at Lower Wyburns Farm in close proximity to the District boundary and connection to the A127 as a location which may be appropriate to meet any unmet need for family housing arising from the wider South Essex region.
8.4. It has been established that Rayleigh benefits from high levels of completeness, with a large percentage of the settlement located within the walking catchment of education, sport, leisure, and health facilities however, the ‘Complete Communities Topic Paper’ identifies that only 18% of Rayleigh is located within the walking catchment of green infrastructure. Previous representations made to the Authority promoting the land at Lower Wyburns Farm have identified that the site’s development will include provision of an area of public open space to the north west of the site. As such, it is considered that the allocation of the site will both continue to ensure that development at Rayleigh is located in the most sustainable locations, that are areas within the walking catchment of a good range of services and facilities, whilst also seeking to address deficiencies in green infrastructure provision in Rayleigh.
Enclosed: Site Location Plan: Lower Wyburns Farm, Daws Heath Road, Rayleigh
:Dwg SK001 Illustrative Masterplan

ROCHFORD NEW LOCAL PLAN: SPATIAL OPTIONS CONSULTATION- SUBMISSION OF REPRESENTATIONS ON BEHALF OF SOUTHERN & REGIONAL DEVELOPMENTS LIMITED
Claremont Planning Consultancy have been instructed by Southern and Regional Developments Limited to prepare and submit representations to the new Local Plan: Spatial Options consultation.
Southern and Regional Developments are in control of two sites within the Rochford District; the land at Lower Wyburns Farm, Rayleigh, and Sutton Road, Rochford, with both sites previously promoted to the Council through the 2018 Call for Sites exercise for the emerging
Local Plan. For clarity, it has therefore been considered prudent to prepare and submit representations to the Spatial Options consultation separately considering each site separately.
As such, please find the following sets of representations enclosed:
• Lower Wyburns Farm representations to Spatial Options- Location Plan and Illustrative
Masterplan enclosed.
• Sutton Road representations to Spatial Options - Location Plan enclosed
We trust that these representations are clear and will be duly taken into consideration, however, if Southern and Regional Developments or Claremont Planning can assist with providing any further information in relation to the sites at Lower Wyburns Farm and Sutton Road, or the content of the representations submitted, please do not hesitate to contact me on the details below.

Rochford District Council – Lower Wyburns Farm, Rayleigh
Representations to the Spatial Options
1. Introduction
1.1. On behalf of Southern and Regional Developments Ltd, Claremont Planning Consultancy has been instructed to prepare and submit representations to the Spatial Options consultation being undertaken by Rochford District Council to inform the emerging Local
Plan.

2. Strategy Options
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?

2.1. Claremont Planning, on behalf of Southern and Regional Development’s Ltd, are supportive of the settlement hierarchy proposed. The identification of Rayleigh as the only ‘Tier 1’ settlement within the District is supported, finding this proportionate to the settlement’s larger population and comprehensive service base, which is of both local and regional prominence. The proposed settlement hierarchy correctly recognises the strategic location of Rayleigh which affords the settlement a functional relationship with the adjacent
Southend, Basildon, Chelmsford, and London Districts.
2.2. It is recommended that the spatial strategy advanced by the emerging Local Plan be strongly informed by the proposed settlement hierarchy. The proposed hierarchy of settlements evidences that Rayleigh benefits from a wide range of retail, employment, and community facilities and therefore represents a highly sustainable location for development. In accordance with the provisions of Paragraph 16 of the National Planning
Policy Framework (NPPF), development plans should be prepared with the objective of contributing to the achievement of sustainable development. As such, it is advisable that the overall distribution of growth is informed by this imperative, and a larger quantum of
growth apportioned to those settlements which are identified by the hierarchy as being most sustainable, chiefly Rayleigh. To accommodate the necessary growth of Rayleigh a full review of the settlement boundary should be undertaken through this plan review process, with Green Belt release of suitable sites promoted to ensure that Rayleigh can accommodate the level of growth its position in the settlement hierarchy requires.

Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
Strategy Option 1: Urban Intensification
2.3. It is advised that Strategy Option 1: Urban Intensification is not advanced on its own. The current standard method identifies a housing requirement of 7,200 dwellings for the district across the next 20 years, however the consultation document establishes that only 4,500 new dwellings can be delivered through Option 1. Paragraph 35 of the NPPF identifies that Plans must provide a strategy which as a minimum seeks to meet the area’s objectively assessed needs in order to be found sound. Delivering development through Strategy Option 1 will result in a substantial shortfall in housing delivery and will unlikely be considered sound by the Inspector when the Plan is examined.
Strategy Option 2: Urban Extensions
2.4. It is recognised that Strategy Option 2, which seeks to spread development across several development sites of between 10 and 1,500 homes adjoining existing towns and villages, could deliver a sustainable distribution of housing growth. The dispersal of urban extensions based on the settlement hierarchy is supported, where this would see growth delivered at the most sustainable settlements in the District. In accordance with the proposed settlement hierarchy, the allocation of urban extensions at Rayleigh, the District’s largest and most sustainable settlement, should be prioritised if this option is taken forward. When considering urban extensions, they should not prohibit the appropriate review of a settlement’s boundary and site releases from the Green Belt for development elsewhere. Co-ordinating urban extensions that are typically large scale developments
alongside smaller site allocations will facilitate the delivery of small to medium sites as advised by the NPPF at Paragraph 69; which will enable the continual supply of housing through a maintained trajectory.
Strategy Option 3: Concentrated Growth
2.5. Concentrating growth in one or more locations of 1,500+ dwellings, as promoted within Strategy Option 3 is not supported on its own at this time. Large allocations and the development of new settlements, by virtue of their complexity and infrastructure requirements, have much longer lead in times for delivery and therefore would be likely to contribute towards meeting housing needs towards the end of the Plan period and beyond.
As such, pursuit of this Strategy Option alone will not deliver sufficient housing to meet the Authority’s housing needs in the earlier years of the Plan, leaving the Authority vulnerable to speculative development which is not Plan lead particularly if delays in the delivery of
these allocations arise. Topic Paper 9: Housing prepared in support of the Spatial Options Consultation 2021 illustrates that over the last 10 years Rochford’s historic rate of housing delivery is 227 dwellings per annum, requiring an uplift of around 60% in annual housing
completions to meet the local housing need identified for the new Local Plan. The Authority should note that paragraph 69 of the NPPF advises against the concentration of growth as proposed within Strategy Option 3, instead recommending that development plans should seek to accommodate at least 10% of their housing requirement on sites no larger than one hectare. Given the uplift in housing delivery which will be required to meet housing need, it would be prudent that the Council also consider the allocation of small and
medium sized sites, such as the promoted land at Lower Wyburns Farm, which can contribute directly to the next 5 year supply and be delivered quickly, making a more
immediate contribution to housing supply alongside this Strategy.
Strategy Option 4: Balanced Combination
2.6. Strategy Option 4 advances a balanced combination of the various Strategy Options presented, including making the best use of urban capacity (Option 1), building on one or two large growth areas (Option 3), and a number of smaller urban extensions (Option 2).
Claremont Planning strongly recommend that the Authority pursue the blended approach promoted within Option 4. It is considered that Option 4 represents the most sustainable means of meeting the District’s housing requirement, by maximising sites available within the existing urban area, and delivering smaller urban extensions at sustainable locations in accordance with the proposed settlement hierarchy. Paragraph 69 of the NPPF establishes that a blended approach which allocates small, medium, and larger sites for development is advisable, ensuring that any potential delays in the delivery of larger allocations do not
adversely affect housing delivery in the District.
2.7. Paragraph 35 of the NPPF sets out the tests for ‘soundness’ of development plans, establishing that plans should, as a minimum, seek to meet their areas objectively assessed housing need and be informed by agreements with other authorities so that any unmet need from neighbouring areas can be accommodated where it is practical to do so. The southern and northern parcels of the land promoted by Southern and Regional
Developments at Lower Wyburns Farm have been recognised by the Council within their Site Assessment Paper 2021, with references CFS068 and CFS069 respectively; for their potential to deliver growth through Option 2, small urban extensions. Claremont Planning
strongly support the Council’s recognition of the land’s potential and note that the land occupies a highly sustainable location adjacent to the District’s only Tier 1 settlement.
Furthermore, the promoted site should be recognised as a suitable location which could contribute towards unmet need arising from neighbouring authorities due to its close geographical proximity to adjacent districts, particularly to the Castle Point Borough and
Southend-on-Sea Districts, whilst also benefitting from a close functional relationship these due to its proximity to the strategic highway network, namely the A127.

3. Spatial Themes
Q9. Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and
coastal change wherever possible? How can we best protect current and future communities from flood risk and coastal change?

3.1. National policy, chiefly paragraph 161 of the NPPF, is clear in its expectations that development plans apply a sequential, risk-based approach to the location of development which includes taking into account all sources of flood risk as well as current and future
impacts of climate change. As such, it is agreed that a sequential approach to flood risk and coastal change should be adopted by the Plan, and this would be a sound approach that is consistent with national planning policy. As recognised by the Council, much of the
District is affected by Flood Zone 3 with flood risk likely to be subject to coastal change as a result of climate change. As such, it is recommended that development opportunities within areas at lower risk of flooding are fully considered by the Authority. Approaching flood risk and coastal change sequentially would also accord with the proposed settlement hierarchy, concentrating development at the main settlements of the District, including Rayleigh which are the areas within the District at lower risk of flooding.
3.2. The land at Lower Wyburns Farm, Daws Heath Road represents one such suitable location for development if the sequential approach to flood risk is adopted. With respect to the parcel of land south of Daws Heath Road, only a very small area along Daws Heath Road, is affected by Flood Zone 2. With respect to the promoted parcel of land north of the road, this is more heavily influenced by flood risk, being completely covered by Flood Zones 2 and 3. Previous representations submitted to the Council through the SHLAA/Call for Sites process by Claremont Planning have considered the flood risk present on the site at length and it is advanced that the flood zone 3 areas should be removed from consideration for development and instead contribute toward public open space provision and ecological enhancement measures. Any development on the northern parcel should be focused upon redeveloping the existing dwelling on the site, away from the flood prone
areas and towards the frontage with Daws Heath Road.
3.3. When assessing the flood risk of the promoted land at Lower Wyburns Farm within their initial site assessments, the Council also recognise that the majority of the promoted land is at low risk of flooding, scoring the northern and southern parcels of the site as 3 and 4 respectively for flood risk on a scale on for which 5 represents the best performing sites.
Given that the vast majority of the promoted land at Lower Wyburns Farm south of Daws Heath Road is located within Flood Zone 1, and the Council’s recognition that the site performs strongly in respect of flood risk; Claremont Planning consider that the
development of this land would be in accordance with the recommended sequential approach to flood risk in the Plan.

4. Housing for All
Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes, and tenures of housing?

4.1. Meeting the need for different types, sizes, and tenures of housing by requiring a suitable or negotiable mix of housing that is responsive to the type and location of development, as promoted by Option 2, is recommended by Claremont Planning. It is considered that this represents the most pragmatic approach to meeting these needs by providing flexibility in the market to ensure that the right types of homes are delivered in the right locations. Applying a blanket housing mix policy would fail to recognise that some types of land are
more well suited to certain forms of development. For example, both the Housing Topic Paper 2021 and 2017 SHMA establish that there is the greatest need for small and midsized semi-detached and detached dwellings. Claremont Planning consider that the release of Green Belt land, including the site at Lower Wyburns Farm should be strongly considered by the Council whereby the release of this land will both assist the Council in
meeting their overall housing need and facilitate the delivery of an appropriate mix of housing. In particular this will assist delivery of family sized housing which is better suited to delivery on greenfield land than constrained urban sites.

5. Green and Blue Infrastructure
Q32. With reference to the options above, or your own options, how do you feel we can best deliver quality green and blue infrastructure network throughout the Plan?
5.1. The Green and Blue Infrastructure Topic Paper 2021 identifies that previous housing and economic growth throughout South Essex has not been sufficient to meet the region’s growth potential. As such, Claremont Planning maintain that although delivering quality
green and blue infrastructure is valuable, this must be balanced against the region’s need for growth. It is therefore recommended that identifying general objectives for strategic green and blue infrastructure through the plan (Option 2) is pursued by the Authority, with this Option relying on other existing allocations, such as open space, local green space, and local wildlife site designations to deliver improvements. The suggestion identified within the Topic Paper that the Plan could still contain policies that help to deliver improvements to green and blue infrastructure, including the capture of funding through planning obligations associated with development is recommended to be advanced
alongside this approach. Advancing Option 2 would continue to promote the delivery of improvements on site where appropriate, without constraining the ability of development to make the most effective use on land by requiring on-site improvements to be delivered.
Moreover, it is not considered that detailed, site-specific policies are relevant for inclusion within a strategic plan of this nature where national planning policy establishes in Chapter 3 of the NPPF the role that strategic policies should play, which is to set the overall strategies for the pattern, scale and design quality of places. As such, policies relating to site specific provision of green and blue infrastructure would be more appropriately dealt
with through the preparation non-strategic level Plans and Policies such as those in Neighbourhood Plans.
5.2. The Green and Blue Infrastructure Topic Paper 2021 also establishes that the connectivity of green and blue infrastructure is challenging, with many poor green and blue linkages between towns, villages, rural areas and waterfronts. Whilst Option 3, requiring certain new
developments to provide local green and blue infrastructure on-site, may increase the quantum of green and blue infrastructure throughout Rochford, there is risk that this may worsen the connectivity of these spaces through their piecemeal development.
Contrastingly, securing funding through planning obligations as part of Option 2 could deliver strategic improvements to this network to be made in accordance with a wider vision for the area. This would represent a more effective and deliverable strategy, meeting that criteria for soundness as identified in the NPPF.

6. Town Centres and Retail
Q46. With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley?
How can we also ensure our village and neighbourhood centres remain vibrant?
6.1. Claremont Planning support the ambition of Options 5 and 10 in their recognition that delivering a suitable mix of uses including residential development is essential in
continuing to support the vitality and viability of town centres. It is considered important however, that the Council recognise the importance of allowing settlements to expand through new development outside of the existing settlement boundary, as this can allow the population of settlements to grow. This in turn can increase footfall to existing shops and services, and enhance the vitality and viability of these settlements, especially where good pedestrian connectivity to the town centre is present. Whilst it is recognised that the
consultation document identifies that town centres within the District have not suffered declines in footfall as acutely as national trends would indicate, further development and growth at a settlement could ensure that town centres remain sustainable in the future.

7. Green Belt and Rural Issues – Plan Objective 20 (p.69-70)
7.1. The recognition that the release of Green Belt land will be required to meet housing needs through the emerging Plan is strongly supported. It is agreed that the Council can demonstrate the exceptional circumstances necessary to justify this release, in accordance with paragraph 141 of the NPPF. The Consultation Document has sought to establish that a spatial strategy reliant on urban intensification will not deliver sufficient housing to meet the Council’s objectively assessed need and confirms that early discussions with adjacent authorities has not identified capacity for accommodating unmet need arising from Rochford. As such, it is agreed and supported that the emerging Local Plan will be able to
demonstrate the exceptional circumstances necessary to justify the release of Green Belt land.
7.2. The Rochford District and Southend-on-Sea Joint Green Belt Study (February 2020) forming the evidence base to this consultation contains detailed site assessments that identify the contribution made by promoted sites to the purposes of the Green Belt. Within
this report, the land at Lower Wyburns Farm was assessed as making a strong contribution to the purposes of the Green Belt, finding that the site presents a strong openness and has a closer relationship with the surrounding countryside than the urban area. Likewise, the initial assessment proformas prepared by the Authority also rated the identified site as relatively strongly performing Green Belt. These conclusions are refuted and it is considered that these assessments failed to recognise several key features of the promoted land which diminish its contribution to the Green Belt. Notably, assessments of the land around the site have failed to identify that both the north and south parcels of the site are currently in use and developed; with the original farmhouse and livery stables in the southern parcel alongside a range of buildings and yards that accommodate B2 Industrial uses with external storage areas and further Sui Generis horticultural and
residential uses located within the northern parcel. As such, a large quantum of the promoted site’s area represents previously developed land and should be prioritised for development.
7.3. The Joint Green Belt Study however establishes that the environmental and sustainability effects of development need to be considered when releasing land from the Green Belt, where it may be that the most sustainable locations for development may not be
appropriate or sustainable, with this pragmatic approach to Green Belt release strongly supported by Claremont Planning where it accords with the provisions of paragraph 142 of the NPPF. Specifically, paragraph 142 of the Framework recommends that plans should give first consideration to land which is previously developed and/or well served by public transport when considering Green Belt release. It has been established that a proportion of the land promoted by Southern and Regional Developments at Lower Wyburns Farm
represents previously developed land, as previously recognised in the Council’s 2017 SHELAA assessment of the southern parcel (CFS068), with built form existing on the southern parcel of the site in particular with a variety of B2 industrial sheds alongside an established concrete hardstanding and occupied by structures extending up to two stories in height, obscuring any view of the wider countryside and significantly reducing the land’s openness. Moreover, the industrial units occupying the land at present host a variety of established uses, including a lawn mower repair shop and vehicle servicing, alongside a camping and caravan site, whilst the northern parcel of land is used as a plant nursery. As
such, both parcels benefit from established activity and transport movements further reducing openness characteristics attributed to the site.
7.4. At present the Green Belt Study does not adequately consider the characteristics of the site with respect to its established uses, built form and recognitions as previously developed land. This is demonstrated through the Parcel Assessments included in the Green Belt Study, with the promoted land included incorrectly within Parcel 21 alongside undeveloped farmland. The parcel sizes identified through the study vary considerably in
shape and size, with specific characteristics of land informing the parcel sizes. An example of this and the resulting assessment of Green Belt factors is Parcel P29 that covers the land off Rayleigh Down Road and The Drive, where residential buildings and area of external caravan storage alongside/ horticultural/agricultural buildings have been recognised within a smaller parcel area and assessed as having less contribution to
Green Belt as a result. This approach of applying a smaller parcel should also have been identifeid for the land at Lower Wyburns Farm, which would have enabled its assessment separately from the woodland, playing fields and pasture that makes up the rest of parcel
21 to the east. The Green Belt Study undertaken has therefore not allowed for the appropriate assessment of edge of settlement sites that would otherwise be considered as sustainable allocation options and be taken forward for further consideration through the
Local Plan process.
7.5. The reduced openness and lack of rural character afforded by the existing structures on site reduces the land’s contribution to the Green Belt considerably. In accordance with the principles established by the Joint Green Belt Study, alongside the reduced contribution of
the land to the purposes of the Green Belt, the highly sustainable location of the site adjacent to Rayleigh and the accessibility of local services and facilities from the site, should also ensure that the land at Lower Wyburns Farm is identified as a suitable candidate for Green Belt release.

Q56b. With reference to Figure 44 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses?
How could that improve the completeness of Rayleigh?
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community Infrastructure [open space, education, healthcare, allotments, other]
4. Other

8.2. Promoted sites CFS068 and CFS069 (Land at Lower Wyburns Farm) identified on Figure 44 should be made available for residential development. Although land at Lower Wyburns Farm promoted by Southern and Regional Developments is not identified on the walking completeness score map presented within the ‘Complete Communities’ Topic Paper, the site is located adjacent to areas afforded attributed a walking completeness score of 8-10 showing that reasonable levels of services and facilities are located within the ‘walking catchment’ of the land. Notwithstanding this, it is recommended that the
Council be pragmatic in applying walking completeness scores where the Topic Paper confirms that being located outside of the comfortable walking catchment for a specific facility does not mean that the facility is inaccessible. This assertion is particularly relevant
for Rayleigh, where the Topic Paper establishes that 56% of the settlement is located within the walking catchment of a frequent bus service. A review of the promoted land’s context confirms that the site is located within a 5 minute walk from existing bus stops sited along the Eastwood Road. These bus stops provide very frequent services to a range of destinations including, Southend-on-Sea, Shoeburyness, Rayleigh, and Basildon Town
Centre. As such, Claremont Planning recommend that the Council recognises the highly sustainable location of the promoted land at Lower Wyburns Farm for residential
development, given both the variety of services and facilities located within the land’s walking catchment, and the site’s close proximity to frequent public transport services.
8.3. Moreover, the vision for Rayleigh advanced by the Consultation Document sets out the ambition to provide for a diverse range of housing which meet the needs of all in the community. The 2017 Strategic Housing Market Assessment (SHMA) establishes that both within Rochford, and across the South Essex region, the greatest additional demand for housing will be generated by households requiring family housing with three bedrooms. As such, it is considered that the release of the land at Lower Wyburns Farm from the Green Belt, and its allocation for residential development can strongly contribute to delivering housing to meet this need where greenfield land is considered to be more appropriate for
the delivery of family-sized housing. It is also advised that the Authority acknowledge the strategic location of the land at Lower Wyburns Farm in close proximity to the District boundary and connection to the A127 as a location which may be appropriate to meet any unmet need for family housing arising from the wider South Essex region.
8.4. It has been established that Rayleigh benefits from high levels of completeness, with a large percentage of the settlement located within the walking catchment of education, sport, leisure, and health facilities however, the ‘Complete Communities Topic Paper’ identifies that only 18% of Rayleigh is located within the walking catchment of green infrastructure. Previous representations made to the Authority promoting the land at Lower Wyburns Farm have identified that the site’s development will include provision of an area of public open space to the north west of the site. As such, it is considered that the allocation of the site will both continue to ensure that development at Rayleigh is located in the most sustainable locations, that are areas within the walking catchment of a good range of services and facilities, whilst also seeking to address deficiencies in green infrastructure provision in Rayleigh.
Enclosed: Site Location Plan: Lower Wyburns Farm, Daws Heath Road, Rayleigh
:Dwg SK001 Illustrative Masterplan

ROCHFORD NEW LOCAL PLAN: SPATIAL OPTIONS CONSULTATION- SUBMISSION OF REPRESENTATIONS ON BEHALF OF SOUTHERN & REGIONAL DEVELOPMENTS LIMITED
Claremont Planning Consultancy have been instructed by Southern and Regional Developments Limited to prepare and submit representations to the new Local Plan: Spatial Options consultation.
Southern and Regional Developments are in control of two sites within the Rochford District; the land at Lower Wyburns Farm, Rayleigh, and Sutton Road, Rochford, with both sites previously promoted to the Council through the 2018 Call for Sites exercise for the emerging
Local Plan. For clarity, it has therefore been considered prudent to prepare and submit representations to the Spatial Options consultation separately considering each site separately.
As such, please find the following sets of representations enclosed:
• Lower Wyburns Farm representations to Spatial Options- Location Plan and Illustrative
Masterplan enclosed.
• Sutton Road representations to Spatial Options - Location Plan enclosed
We trust that these representations are clear and will be duly taken into consideration, however, if Southern and Regional Developments or Claremont Planning can assist with providing any further information in relation to the sites at Lower Wyburns Farm and Sutton Road, or the content of the representations submitted, please do not hesitate to contact me on the details below.

Rochford District Council – Lower Wyburns Farm, Rayleigh
Representations to the Spatial Options
1. Introduction
1.1. On behalf of Southern and Regional Developments Ltd, Claremont Planning Consultancy has been instructed to prepare and submit representations to the Spatial Options consultation being undertaken by Rochford District Council to inform the emerging Local
Plan.

2. Strategy Options
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?

2.1. Claremont Planning, on behalf of Southern and Regional Development’s Ltd, are supportive of the settlement hierarchy proposed. The identification of Rayleigh as the only ‘Tier 1’ settlement within the District is supported, finding this proportionate to the settlement’s larger population and comprehensive service base, which is of both local and regional prominence. The proposed settlement hierarchy correctly recognises the strategic location of Rayleigh which affords the settlement a functional relationship with the adjacent
Southend, Basildon, Chelmsford, and London Districts.
2.2. It is recommended that the spatial strategy advanced by the emerging Local Plan be strongly informed by the proposed settlement hierarchy. The proposed hierarchy of settlements evidences that Rayleigh benefits from a wide range of retail, employment, and community facilities and therefore represents a highly sustainable location for development. In accordance with the provisions of Paragraph 16 of the National Planning
Policy Framework (NPPF), development plans should be prepared with the objective of contributing to the achievement of sustainable development. As such, it is advisable that the overall distribution of growth is informed by this imperative, and a larger quantum of
growth apportioned to those settlements which are identified by the hierarchy as being most sustainable, chiefly Rayleigh. To accommodate the necessary growth of Rayleigh a full review of the settlement boundary should be undertaken through this plan review process, with Green Belt release of suitable sites promoted to ensure that Rayleigh can accommodate the level of growth its position in the settlement hierarchy requires.

Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
Strategy Option 1: Urban Intensification
2.3. It is advised that Strategy Option 1: Urban Intensification is not advanced on its own. The current standard method identifies a housing requirement of 7,200 dwellings for the district across the next 20 years, however the consultation document establishes that only 4,500 new dwellings can be delivered through Option 1. Paragraph 35 of the NPPF identifies that Plans must provide a strategy which as a minimum seeks to meet the area’s objectively assessed needs in order to be found sound. Delivering development through Strategy Option 1 will result in a substantial shortfall in housing delivery and will unlikely be considered sound by the Inspector when the Plan is examined.
Strategy Option 2: Urban Extensions
2.4. It is recognised that Strategy Option 2, which seeks to spread development across several development sites of between 10 and 1,500 homes adjoining existing towns and villages, could deliver a sustainable distribution of housing growth. The dispersal of urban extensions based on the settlement hierarchy is supported, where this would see growth delivered at the most sustainable settlements in the District. In accordance with the proposed settlement hierarchy, the allocation of urban extensions at Rayleigh, the District’s largest and most sustainable settlement, should be prioritised if this option is taken forward. When considering urban extensions, they should not prohibit the appropriate review of a settlement’s boundary and site releases from the Green Belt for development elsewhere. Co-ordinating urban extensions that are typically large scale developments
alongside smaller site allocations will facilitate the delivery of small to medium sites as advised by the NPPF at Paragraph 69; which will enable the continual supply of housing through a maintained trajectory.
Strategy Option 3: Concentrated Growth
2.5. Concentrating growth in one or more locations of 1,500+ dwellings, as promoted within Strategy Option 3 is not supported on its own at this time. Large allocations and the development of new settlements, by virtue of their complexity and infrastructure requirements, have much longer lead in times for delivery and therefore would be likely to contribute towards meeting housing needs towards the end of the Plan period and beyond.
As such, pursuit of this Strategy Option alone will not deliver sufficient housing to meet the Authority’s housing needs in the earlier years of the Plan, leaving the Authority vulnerable to speculative development which is not Plan lead particularly if delays in the delivery of
these allocations arise. Topic Paper 9: Housing prepared in support of the Spatial Options Consultation 2021 illustrates that over the last 10 years Rochford’s historic rate of housing delivery is 227 dwellings per annum, requiring an uplift of around 60% in annual housing
completions to meet the local housing need identified for the new Local Plan. The Authority should note that paragraph 69 of the NPPF advises against the concentration of growth as proposed within Strategy Option 3, instead recommending that development plans should seek to accommodate at least 10% of their housing requirement on sites no larger than one hectare. Given the uplift in housing delivery which will be required to meet housing need, it would be prudent that the Council also consider the allocation of small and
medium sized sites, such as the promoted land at Lower Wyburns Farm, which can contribute directly to the next 5 year supply and be delivered quickly, making a more
immediate contribution to housing supply alongside this Strategy.
Strategy Option 4: Balanced Combination
2.6. Strategy Option 4 advances a balanced combination of the various Strategy Options presented, including making the best use of urban capacity (Option 1), building on one or two large growth areas (Option 3), and a number of smaller urban extensions (Option 2).
Claremont Planning strongly recommend that the Authority pursue the blended approach promoted within Option 4. It is considered that Option 4 represents the most sustainable means of meeting the District’s housing requirement, by maximising sites available within the existing urban area, and delivering smaller urban extensions at sustainable locations in accordance with the proposed settlement hierarchy. Paragraph 69 of the NPPF establishes that a blended approach which allocates small, medium, and larger sites for development is advisable, ensuring that any potential delays in the delivery of larger allocations do not
adversely affect housing delivery in the District.
2.7. Paragraph 35 of the NPPF sets out the tests for ‘soundness’ of development plans, establishing that plans should, as a minimum, seek to meet their areas objectively assessed housing need and be informed by agreements with other authorities so that any unmet need from neighbouring areas can be accommodated where it is practical to do so. The southern and northern parcels of the land promoted by Southern and Regional
Developments at Lower Wyburns Farm have been recognised by the Council within their Site Assessment Paper 2021, with references CFS068 and CFS069 respectively; for their potential to deliver growth through Option 2, small urban extensions. Claremont Planning
strongly support the Council’s recognition of the land’s potential and note that the land occupies a highly sustainable location adjacent to the District’s only Tier 1 settlement.
Furthermore, the promoted site should be recognised as a suitable location which could contribute towards unmet need arising from neighbouring authorities due to its close geographical proximity to adjacent districts, particularly to the Castle Point Borough and
Southend-on-Sea Districts, whilst also benefitting from a close functional relationship these due to its proximity to the strategic highway network, namely the A127.

3. Spatial Themes
Q9. Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and
coastal change wherever possible? How can we best protect current and future communities from flood risk and coastal change?

3.1. National policy, chiefly paragraph 161 of the NPPF, is clear in its expectations that development plans apply a sequential, risk-based approach to the location of development which includes taking into account all sources of flood risk as well as current and future
impacts of climate change. As such, it is agreed that a sequential approach to flood risk and coastal change should be adopted by the Plan, and this would be a sound approach that is consistent with national planning policy. As recognised by the Council, much of the
District is affected by Flood Zone 3 with flood risk likely to be subject to coastal change as a result of climate change. As such, it is recommended that development opportunities within areas at lower risk of flooding are fully considered by the Authority. Approaching flood risk and coastal change sequentially would also accord with the proposed settlement hierarchy, concentrating development at the main settlements of the District, including Rayleigh which are the areas within the District at lower risk of flooding.
3.2. The land at Lower Wyburns Farm, Daws Heath Road represents one such suitable location for development if the sequential approach to flood risk is adopted. With respect to the parcel of land south of Daws Heath Road, only a very small area along Daws Heath Road, is affected by Flood Zone 2. With respect to the promoted parcel of land north of the road, this is more heavily influenced by flood risk, being completely covered by Flood Zones 2 and 3. Previous representations submitted to the Council through the SHLAA/Call for Sites process by Claremont Planning have considered the flood risk present on the site at length and it is advanced that the flood zone 3 areas should be removed from consideration for development and instead contribute toward public open space provision and ecological enhancement measures. Any development on the northern parcel should be focused upon redeveloping the existing dwelling on the site, away from the flood prone
areas and towards the frontage with Daws Heath Road.
3.3. When assessing the flood risk of the promoted land at Lower Wyburns Farm within their initial site assessments, the Council also recognise that the majority of the promoted land is at low risk of flooding, scoring the northern and southern parcels of the site as 3 and 4 respectively for flood risk on a scale on for which 5 represents the best performing sites.
Given that the vast majority of the promoted land at Lower Wyburns Farm south of Daws Heath Road is located within Flood Zone 1, and the Council’s recognition that the site performs strongly in respect of flood risk; Claremont Planning consider that the
development of this land would be in accordance with the recommended sequential approach to flood risk in the Plan.

4. Housing for All
Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes, and tenures of housing?

4.1. Meeting the need for different types, sizes, and tenures of housing by requiring a suitable or negotiable mix of housing that is responsive to the type and location of development, as promoted by Option 2, is recommended by Claremont Planning. It is considered that this represents the most pragmatic approach to meeting these needs by providing flexibility in the market to ensure that the right types of homes are delivered in the right locations. Applying a blanket housing mix policy would fail to recognise that some types of land are
more well suited to certain forms of development. For example, both the Housing Topic Paper 2021 and 2017 SHMA establish that there is the greatest need for small and midsized semi-detached and detached dwellings. Claremont Planning consider that the release of Green Belt land, including the site at Lower Wyburns Farm should be strongly considered by the Council whereby the release of this land will both assist the Council in
meeting their overall housing need and facilitate the delivery of an appropriate mix of housing. In particular this will assist delivery of family sized housing which is better suited to delivery on greenfield land than constrained urban sites.

5. Green and Blue Infrastructure
Q32. With reference to the options above, or your own options, how do you feel we can best deliver quality green and blue infrastructure network throughout the Plan?
5.1. The Green and Blue Infrastructure Topic Paper 2021 identifies that previous housing and economic growth throughout South Essex has not been sufficient to meet the region’s growth potential. As such, Claremont Planning maintain that although delivering quality
green and blue infrastructure is valuable, this must be balanced against the region’s need for growth. It is therefore recommended that identifying general objectives for strategic green and blue infrastructure through the plan (Option 2) is pursued by the Authority, with this Option relying on other existing allocations, such as open space, local green space, and local wildlife site designations to deliver improvements. The suggestion identified within the Topic Paper that the Plan could still contain policies that help to deliver improvements to green and blue infrastructure, including the capture of funding through planning obligations associated with development is recommended to be advanced
alongside this approach. Advancing Option 2 would continue to promote the delivery of improvements on site where appropriate, without constraining the ability of development to make the most effective use on land by requiring on-site improvements to be delivered.
Moreover, it is not considered that detailed, site-specific policies are relevant for inclusion within a strategic plan of this nature where national planning policy establishes in Chapter 3 of the NPPF the role that strategic policies should play, which is to set the overall strategies for the pattern, scale and design quality of places. As such, policies relating to site specific provision of green and blue infrastructure would be more appropriately dealt
with through the preparation non-strategic level Plans and Policies such as those in Neighbourhood Plans.
5.2. The Green and Blue Infrastructure Topic Paper 2021 also establishes that the connectivity of green and blue infrastructure is challenging, with many poor green and blue linkages between towns, villages, rural areas and waterfronts. Whilst Option 3, requiring certain new
developments to provide local green and blue infrastructure on-site, may increase the quantum of green and blue infrastructure throughout Rochford, there is risk that this may worsen the connectivity of these spaces through their piecemeal development.
Contrastingly, securing funding through planning obligations as part of Option 2 could deliver strategic improvements to this network to be made in accordance with a wider vision for the area. This would represent a more effective and deliverable strategy, meeting that criteria for soundness as identified in the NPPF.

6. Town Centres and Retail
Q46. With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley?
How can we also ensure our village and neighbourhood centres remain vibrant?
6.1. Claremont Planning support the ambition of Options 5 and 10 in their recognition that delivering a suitable mix of uses including residential development is essential in
continuing to support the vitality and viability of town centres. It is considered important however, that the Council recognise the importance of allowing settlements to expand through new development outside of the existing settlement boundary, as this can allow the population of settlements to grow. This in turn can increase footfall to existing shops and services, and enhance the vitality and viability of these settlements, especially where good pedestrian connectivity to the town centre is present. Whilst it is recognised that the
consultation document identifies that town centres within the District have not suffered declines in footfall as acutely as national trends would indicate, further development and growth at a settlement could ensure that town centres remain sustainable in the future.

7. Green Belt and Rural Issues – Plan Objective 20 (p.69-70)
7.1. The recognition that the release of Green Belt land will be required to meet housing needs through the emerging Plan is strongly supported. It is agreed that the Council can demonstrate the exceptional circumstances necessary to justify this release, in accordance with paragraph 141 of the NPPF. The Consultation Document has sought to establish that a spatial strategy reliant on urban intensification will not deliver sufficient housing to meet the Council’s objectively assessed need and confirms that early discussions with adjacent authorities has not identified capacity for accommodating unmet need arising from Rochford. As such, it is agreed and supported that the emerging Local Plan will be able to
demonstrate the exceptional circumstances necessary to justify the release of Green Belt land.
7.2. The Rochford District and Southend-on-Sea Joint Green Belt Study (February 2020) forming the evidence base to this consultation contains detailed site assessments that identify the contribution made by promoted sites to the purposes of the Green Belt. Within
this report, the land at Lower Wyburns Farm was assessed as making a strong contribution to the purposes of the Green Belt, finding that the site presents a strong openness and has a closer relationship with the surrounding countryside than the urban area. Likewise, the initial assessment proformas prepared by the Authority also rated the identified site as relatively strongly performing Green Belt. These conclusions are refuted and it is considered that these assessments failed to recognise several key features of the promoted land which diminish its contribution to the Green Belt. Notably, assessments of the land around the site have failed to identify that both the north and south parcels of the site are currently in use and developed; with the original farmhouse and livery stables in the southern parcel alongside a range of buildings and yards that accommodate B2 Industrial uses with external storage areas and further Sui Generis horticultural and
residential uses located within the northern parcel. As such, a large quantum of the promoted site’s area represents previously developed land and should be prioritised for development.
7.3. The Joint Green Belt Study however establishes that the environmental and sustainability effects of development need to be considered when releasing land from the Green Belt, where it may be that the most sustainable locations for development may not be
appropriate or sustainable, with this pragmatic approach to Green Belt release strongly supported by Claremont Planning where it accords with the provisions of paragraph 142 of the NPPF. Specifically, paragraph 142 of the Framework recommends that plans should give first consideration to land which is previously developed and/or well served by public transport when considering Green Belt release. It has been established that a proportion of the land promoted by Southern and Regional Developments at Lower Wyburns Farm
represents previously developed land, as previously recognised in the Council’s 2017 SHELAA assessment of the southern parcel (CFS068), with built form existing on the southern parcel of the site in particular with a variety of B2 industrial sheds alongside an established concrete hardstanding and occupied by structures extending up to two stories in height, obscuring any view of the wider countryside and significantly reducing the land’s openness. Moreover, the industrial units occupying the land at present host a variety of established uses, including a lawn mower repair shop and vehicle servicing, alongside a camping and caravan site, whilst the northern parcel of land is used as a plant nursery. As
such, both parcels benefit from established activity and transport movements further reducing openness characteristics attributed to the site.
7.4. At present the Green Belt Study does not adequately consider the characteristics of the site with respect to its established uses, built form and recognitions as previously developed land. This is demonstrated through the Parcel Assessments included in the Green Belt Study, with the promoted land included incorrectly within Parcel 21 alongside undeveloped farmland. The parcel sizes identified through the study vary considerably in
shape and size, with specific characteristics of land informing the parcel sizes. An example of this and the resulting assessment of Green Belt factors is Parcel P29 that covers the land off Rayleigh Down Road and The Drive, where residential buildings and area of external caravan storage alongside/ horticultural/agricultural buildings have been recognised within a smaller parcel area and assessed as having less contribution to
Green Belt as a result. This approach of applying a smaller parcel should also have been identifeid for the land at Lower Wyburns Farm, which would have enabled its assessment separately from the woodland, playing fields and pasture that makes up the rest of parcel
21 to the east. The Green Belt Study undertaken has therefore not allowed for the appropriate assessment of edge of settlement sites that would otherwise be considered as sustainable allocation options and be taken forward for further consideration through the
Local Plan process.
7.5. The reduced openness and lack of rural character afforded by the existing structures on site reduces the land’s contribution to the Green Belt considerably. In accordance with the principles established by the Joint Green Belt Study, alongside the reduced contribution of
the land to the purposes of the Green Belt, the highly sustainable location of the site adjacent to Rayleigh and the accessibility of local services and facilities from the site, should also ensure that the land at Lower Wyburns Farm is identified as a suitable candidate for Green Belt release.

Q56b. With reference to Figure 44 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses?
How could that improve the completeness of Rayleigh?
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community Infrastructure [open space, education, healthcare, allotments, other]
4. Other

8.2. Promoted sites CFS068 and CFS069 (Land at Lower Wyburns Farm) identified on Figure 44 should be made available for residential development. Although land at Lower Wyburns Farm promoted by Southern and Regional Developments is not identified on the walking completeness score map presented within the ‘Complete Communities’ Topic Paper, the site is located adjacent to areas afforded attributed a walking completeness score of 8-10 showing that reasonable levels of services and facilities are located within the ‘walking catchment’ of the land. Notwithstanding this, it is recommended that the
Council be pragmatic in applying walking completeness scores where the Topic Paper confirms that being located outside of the comfortable walking catchment for a specific facility does not mean that the facility is inaccessible. This assertion is particularly relevant
for Rayleigh, where the Topic Paper establishes that 56% of the settlement is located within the walking catchment of a frequent bus service. A review of the promoted land’s context confirms that the site is located within a 5 minute walk from existing bus stops sited along the Eastwood Road. These bus stops provide very frequent services to a range of destinations including, Southend-on-Sea, Shoeburyness, Rayleigh, and Basildon Town
Centre. As such, Claremont Planning recommend that the Council recognises the highly sustainable location of the promoted land at Lower Wyburns Farm for residential
development, given both the variety of services and facilities located within the land’s walking catchment, and the site’s close proximity to frequent public transport services.
8.3. Moreover, the vision for Rayleigh advanced by the Consultation Document sets out the ambition to provide for a diverse range of housing which meet the needs of all in the community. The 2017 Strategic Housing Market Assessment (SHMA) establishes that both within Rochford, and across the South Essex region, the greatest additional demand for housing will be generated by households requiring family housing with three bedrooms. As such, it is considered that the release of the land at Lower Wyburns Farm from the Green Belt, and its allocation for residential development can strongly contribute to delivering housing to meet this need where greenfield land is considered to be more appropriate for
the delivery of family-sized housing. It is also advised that the Authority acknowledge the strategic location of the land at Lower Wyburns Farm in close proximity to the District boundary and connection to the A127 as a location which may be appropriate to meet any unmet need for family housing arising from the wider South Essex region.
8.4. It has been established that Rayleigh benefits from high levels of completeness, with a large percentage of the settlement located within the walking catchment of education, sport, leisure, and health facilities however, the ‘Complete Communities Topic Paper’ identifies that only 18% of Rayleigh is located within the walking catchment of green infrastructure. Previous representations made to the Authority promoting the land at Lower Wyburns Farm have identified that the site’s development will include provision of an area of public open space to the north west of the site. As such, it is considered that the allocation of the site will both continue to ensure that development at Rayleigh is located in the most sustainable locations, that are areas within the walking catchment of a good range of services and facilities, whilst also seeking to address deficiencies in green infrastructure provision in Rayleigh.
Enclosed: Site Location Plan: Lower Wyburns Farm, Daws Heath Road, Rayleigh
:Dwg SK001 Illustrative Masterplan

ROCHFORD NEW LOCAL PLAN: SPATIAL OPTIONS CONSULTATION- SUBMISSION OF REPRESENTATIONS ON BEHALF OF SOUTHERN & REGIONAL DEVELOPMENTS LIMITED
Claremont Planning Consultancy have been instructed by Southern and Regional Developments Limited to prepare and submit representations to the new Local Plan: Spatial Options consultation.
Southern and Regional Developments are in control of two sites within the Rochford District; the land at Lower Wyburns Farm, Rayleigh, and Sutton Road, Rochford, with both sites previously promoted to the Council through the 2018 Call for Sites exercise for the emerging
Local Plan. For clarity, it has therefore been considered prudent to prepare and submit representations to the Spatial Options consultation separately considering each site separately.
As such, please find the following sets of representations enclosed:
• Lower Wyburns Farm representations to Spatial Options- Location Plan and Illustrative
Masterplan enclosed.
• Sutton Road representations to Spatial Options - Location Plan enclosed
We trust that these representations are clear and will be duly taken into consideration, however, if Southern and Regional Developments or Claremont Planning can assist with providing any further information in relation to the sites at Lower Wyburns Farm and Sutton Road, or the content of the representations submitted, please do not hesitate to contact me on the details below.

Rochford District Council – Lower Wyburns Farm, Rayleigh
Representations to the Spatial Options
1. Introduction
1.1. On behalf of Southern and Regional Developments Ltd, Claremont Planning Consultancy has been instructed to prepare and submit representations to the Spatial Options consultation being undertaken by Rochford District Council to inform the emerging Local
Plan.

2. Strategy Options
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?

2.1. Claremont Planning, on behalf of Southern and Regional Development’s Ltd, are supportive of the settlement hierarchy proposed. The identification of Rayleigh as the only ‘Tier 1’ settlement within the District is supported, finding this proportionate to the settlement’s larger population and comprehensive service base, which is of both local and regional prominence. The proposed settlement hierarchy correctly recognises the strategic location of Rayleigh which affords the settlement a functional relationship with the adjacent
Southend, Basildon, Chelmsford, and London Districts.
2.2. It is recommended that the spatial strategy advanced by the emerging Local Plan be strongly informed by the proposed settlement hierarchy. The proposed hierarchy of settlements evidences that Rayleigh benefits from a wide range of retail, employment, and community facilities and therefore represents a highly sustainable location for development. In accordance with the provisions of Paragraph 16 of the National Planning
Policy Framework (NPPF), development plans should be prepared with the objective of contributing to the achievement of sustainable development. As such, it is advisable that the overall distribution of growth is informed by this imperative, and a larger quantum of
growth apportioned to those settlements which are identified by the hierarchy as being most sustainable, chiefly Rayleigh. To accommodate the necessary growth of Rayleigh a full review of the settlement boundary should be undertaken through this plan review process, with Green Belt release of suitable sites promoted to ensure that Rayleigh can accommodate the level of growth its position in the settlement hierarchy requires.

Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
Strategy Option 1: Urban Intensification
2.3. It is advised that Strategy Option 1: Urban Intensification is not advanced on its own. The current standard method identifies a housing requirement of 7,200 dwellings for the district across the next 20 years, however the consultation document establishes that only 4,500 new dwellings can be delivered through Option 1. Paragraph 35 of the NPPF identifies that Plans must provide a strategy which as a minimum seeks to meet the area’s objectively assessed needs in order to be found sound. Delivering development through Strategy Option 1 will result in a substantial shortfall in housing delivery and will unlikely be considered sound by the Inspector when the Plan is examined.
Strategy Option 2: Urban Extensions
2.4. It is recognised that Strategy Option 2, which seeks to spread development across several development sites of between 10 and 1,500 homes adjoining existing towns and villages, could deliver a sustainable distribution of housing growth. The dispersal of urban extensions based on the settlement hierarchy is supported, where this would see growth delivered at the most sustainable settlements in the District. In accordance with the proposed settlement hierarchy, the allocation of urban extensions at Rayleigh, the District’s largest and most sustainable settlement, should be prioritised if this option is taken forward. When considering urban extensions, they should not prohibit the appropriate review of a settlement’s boundary and site releases from the Green Belt for development elsewhere. Co-ordinating urban extensions that are typically large scale developments
alongside smaller site allocations will facilitate the delivery of small to medium sites as advised by the NPPF at Paragraph 69; which will enable the continual supply of housing through a maintained trajectory.
Strategy Option 3: Concentrated Growth
2.5. Concentrating growth in one or more locations of 1,500+ dwellings, as promoted within Strategy Option 3 is not supported on its own at this time. Large allocations and the development of new settlements, by virtue of their complexity and infrastructure requirements, have much longer lead in times for delivery and therefore would be likely to contribute towards meeting housing needs towards the end of the Plan period and beyond.
As such, pursuit of this Strategy Option alone will not deliver sufficient housing to meet the Authority’s housing needs in the earlier years of the Plan, leaving the Authority vulnerable to speculative development which is not Plan lead particularly if delays in the delivery of
these allocations arise. Topic Paper 9: Housing prepared in support of the Spatial Options Consultation 2021 illustrates that over the last 10 years Rochford’s historic rate of housing delivery is 227 dwellings per annum, requiring an uplift of around 60% in annual housing
completions to meet the local housing need identified for the new Local Plan. The Authority should note that paragraph 69 of the NPPF advises against the concentration of growth as proposed within Strategy Option 3, instead recommending that development plans should seek to accommodate at least 10% of their housing requirement on sites no larger than one hectare. Given the uplift in housing delivery which will be required to meet housing need, it would be prudent that the Council also consider the allocation of small and
medium sized sites, such as the promoted land at Lower Wyburns Farm, which can contribute directly to the next 5 year supply and be delivered quickly, making a more
immediate contribution to housing supply alongside this Strategy.
Strategy Option 4: Balanced Combination
2.6. Strategy Option 4 advances a balanced combination of the various Strategy Options presented, including making the best use of urban capacity (Option 1), building on one or two large growth areas (Option 3), and a number of smaller urban extensions (Option 2).
Claremont Planning strongly recommend that the Authority pursue the blended approach promoted within Option 4. It is considered that Option 4 represents the most sustainable means of meeting the District’s housing requirement, by maximising sites available within the existing urban area, and delivering smaller urban extensions at sustainable locations in accordance with the proposed settlement hierarchy. Paragraph 69 of the NPPF establishes that a blended approach which allocates small, medium, and larger sites for development is advisable, ensuring that any potential delays in the delivery of larger allocations do not
adversely affect housing delivery in the District.
2.7. Paragraph 35 of the NPPF sets out the tests for ‘soundness’ of development plans, establishing that plans should, as a minimum, seek to meet their areas objectively assessed housing need and be informed by agreements with other authorities so that any unmet need from neighbouring areas can be accommodated where it is practical to do so. The southern and northern parcels of the land promoted by Southern and Regional
Developments at Lower Wyburns Farm have been recognised by the Council within their Site Assessment Paper 2021, with references CFS068 and CFS069 respectively; for their potential to deliver growth through Option 2, small urban extensions. Claremont Planning
strongly support the Council’s recognition of the land’s potential and note that the land occupies a highly sustainable location adjacent to the District’s only Tier 1 settlement.
Furthermore, the promoted site should be recognised as a suitable location which could contribute towards unmet need arising from neighbouring authorities due to its close geographical proximity to adjacent districts, particularly to the Castle Point Borough and
Southend-on-Sea Districts, whilst also benefitting from a close functional relationship these due to its proximity to the strategic highway network, namely the A127.

3. Spatial Themes
Q9. Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and
coastal change wherever possible? How can we best protect current and future communities from flood risk and coastal change?

3.1. National policy, chiefly paragraph 161 of the NPPF, is clear in its expectations that development plans apply a sequential, risk-based approach to the location of development which includes taking into account all sources of flood risk as well as current and future
impacts of climate change. As such, it is agreed that a sequential approach to flood risk and coastal change should be adopted by the Plan, and this would be a sound approach that is consistent with national planning policy. As recognised by the Council, much of the
District is affected by Flood Zone 3 with flood risk likely to be subject to coastal change as a result of climate change. As such, it is recommended that development opportunities within areas at lower risk of flooding are fully considered by the Authority. Approaching flood risk and coastal change sequentially would also accord with the proposed settlement hierarchy, concentrating development at the main settlements of the District, including Rayleigh which are the areas within the District at lower risk of flooding.
3.2. The land at Lower Wyburns Farm, Daws Heath Road represents one such suitable location for development if the sequential approach to flood risk is adopted. With respect to the parcel of land south of Daws Heath Road, only a very small area along Daws Heath Road, is affected by Flood Zone 2. With respect to the promoted parcel of land north of the road, this is more heavily influenced by flood risk, being completely covered by Flood Zones 2 and 3. Previous representations submitted to the Council through the SHLAA/Call for Sites process by Claremont Planning have considered the flood risk present on the site at length and it is advanced that the flood zone 3 areas should be removed from consideration for development and instead contribute toward public open space provision and ecological enhancement measures. Any development on the northern parcel should be focused upon redeveloping the existing dwelling on the site, away from the flood prone
areas and towards the frontage with Daws Heath Road.
3.3. When assessing the flood risk of the promoted land at Lower Wyburns Farm within their initial site assessments, the Council also recognise that the majority of the promoted land is at low risk of flooding, scoring the northern and southern parcels of the site as 3 and 4 respectively for flood risk on a scale on for which 5 represents the best performing sites.
Given that the vast majority of the promoted land at Lower Wyburns Farm south of Daws Heath Road is located within Flood Zone 1, and the Council’s recognition that the site performs strongly in respect of flood risk; Claremont Planning consider that the
development of this land would be in accordance with the recommended sequential approach to flood risk in the Plan.

4. Housing for All
Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes, and tenures of housing?

4.1. Meeting the need for different types, sizes, and tenures of housing by requiring a suitable or negotiable mix of housing that is responsive to the type and location of development, as promoted by Option 2, is recommended by Claremont Planning. It is considered that this represents the most pragmatic approach to meeting these needs by providing flexibility in the market to ensure that the right types of homes are delivered in the right locations. Applying a blanket housing mix policy would fail to recognise that some types of land are
more well suited to certain forms of development. For example, both the Housing Topic Paper 2021 and 2017 SHMA establish that there is the greatest need for small and midsized semi-detached and detached dwellings. Claremont Planning consider that the release of Green Belt land, including the site at Lower Wyburns Farm should be strongly considered by the Council whereby the release of this land will both assist the Council in
meeting their overall housing need and facilitate the delivery of an appropriate mix of housing. In particular this will assist delivery of family sized housing which is better suited to delivery on greenfield land than constrained urban sites.

5. Green and Blue Infrastructure
Q32. With reference to the options above, or your own options, how do you feel we can best deliver quality green and blue infrastructure network throughout the Plan?
5.1. The Green and Blue Infrastructure Topic Paper 2021 identifies that previous housing and economic growth throughout South Essex has not been sufficient to meet the region’s growth potential. As such, Claremont Planning maintain that although delivering quality
green and blue infrastructure is valuable, this must be balanced against the region’s need for growth. It is therefore recommended that identifying general objectives for strategic green and blue infrastructure through the plan (Option 2) is pursued by the Authority, with this Option relying on other existing allocations, such as open space, local green space, and local wildlife site designations to deliver improvements. The suggestion identified within the Topic Paper that the Plan could still contain policies that help to deliver improvements to green and blue infrastructure, including the capture of funding through planning obligations associated with development is recommended to be advanced
alongside this approach. Advancing Option 2 would continue to promote the delivery of improvements on site where appropriate, without constraining the ability of development to make the most effective use on land by requiring on-site improvements to be delivered.
Moreover, it is not considered that detailed, site-specific policies are relevant for inclusion within a strategic plan of this nature where national planning policy establishes in Chapter 3 of the NPPF the role that strategic policies should play, which is to set the overall strategies for the pattern, scale and design quality of places. As such, policies relating to site specific provision of green and blue infrastructure would be more appropriately dealt
with through the preparation non-strategic level Plans and Policies such as those in Neighbourhood Plans.
5.2. The Green and Blue Infrastructure Topic Paper 2021 also establishes that the connectivity of green and blue infrastructure is challenging, with many poor green and blue linkages between towns, villages, rural areas and waterfronts. Whilst Option 3, requiring certain new
developments to provide local green and blue infrastructure on-site, may increase the quantum of green and blue infrastructure throughout Rochford, there is risk that this may worsen the connectivity of these spaces through their piecemeal development.
Contrastingly, securing funding through planning obligations as part of Option 2 could deliver strategic improvements to this network to be made in accordance with a wider vision for the area. This would represent a more effective and deliverable strategy, meeting that criteria for soundness as identified in the NPPF.

6. Town Centres and Retail
Q46. With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley?
How can we also ensure our village and neighbourhood centres remain vibrant?
6.1. Claremont Planning support the ambition of Options 5 and 10 in their recognition that delivering a suitable mix of uses including residential development is essential in
continuing to support the vitality and viability of town centres. It is considered important however, that the Council recognise the importance of allowing settlements to expand through new development outside of the existing settlement boundary, as this can allow the population of settlements to grow. This in turn can increase footfall to existing shops and services, and enhance the vitality and viability of these settlements, especially where good pedestrian connectivity to the town centre is present. Whilst it is recognised that the
consultation document identifies that town centres within the District have not suffered declines in footfall as acutely as national trends would indicate, further development and growth at a settlement could ensure that town centres remain sustainable in the future.

7. Green Belt and Rural Issues – Plan Objective 20 (p.69-70)
7.1. The recognition that the release of Green Belt land will be required to meet housing needs through the emerging Plan is strongly supported. It is agreed that the Council can demonstrate the exceptional circumstances necessary to justify this release, in accordance with paragraph 141 of the NPPF. The Consultation Document has sought to establish that a spatial strategy reliant on urban intensification will not deliver sufficient housing to meet the Council’s objectively assessed need and confirms that early discussions with adjacent authorities has not identified capacity for accommodating unmet need arising from Rochford. As such, it is agreed and supported that the emerging Local Plan will be able to
demonstrate the exceptional circumstances necessary to justify the release of Green Belt land.
7.2. The Rochford District and Southend-on-Sea Joint Green Belt Study (February 2020) forming the evidence base to this consultation contains detailed site assessments that identify the contribution made by promoted sites to the purposes of the Green Belt. Within
this report, the land at Lower Wyburns Farm was assessed as making a strong contribution to the purposes of the Green Belt, finding that the site presents a strong openness and has a closer relationship with the surrounding countryside than the urban area. Likewise, the initial assessment proformas prepared by the Authority also rated the identified site as relatively strongly performing Green Belt. These conclusions are refuted and it is considered that these assessments failed to recognise several key features of the promoted land which diminish its contribution to the Green Belt. Notably, assessments of the land around the site have failed to identify that both the north and south parcels of the site are currently in use and developed; with the original farmhouse and livery stables in the southern parcel alongside a range of buildings and yards that accommodate B2 Industrial uses with external storage areas and further Sui Generis horticultural and
residential uses located within the northern parcel. As such, a large quantum of the promoted site’s area represents previously developed land and should be prioritised for development.
7.3. The Joint Green Belt Study however establishes that the environmental and sustainability effects of development need to be considered when releasing land from the Green Belt, where it may be that the most sustainable locations for development may not be
appropriate or sustainable, with this pragmatic approach to Green Belt release strongly supported by Claremont Planning where it accords with the provisions of paragraph 142 of the NPPF. Specifically, paragraph 142 of the Framework recommends that plans should give first consideration to land which is previously developed and/or well served by public transport when considering Green Belt release. It has been established that a proportion of the land promoted by Southern and Regional Developments at Lower Wyburns Farm
represents previously developed land, as previously recognised in the Council’s 2017 SHELAA assessment of the southern parcel (CFS068), with built form existing on the southern parcel of the site in particular with a variety of B2 industrial sheds alongside an established concrete hardstanding and occupied by structures extending up to two stories in height, obscuring any view of the wider countryside and significantly reducing the land’s openness. Moreover, the industrial units occupying the land at present host a variety of established uses, including a lawn mower repair shop and vehicle servicing, alongside a camping and caravan site, whilst the northern parcel of land is used as a plant nursery. As
such, both parcels benefit from established activity and transport movements further reducing openness characteristics attributed to the site.
7.4. At present the Green Belt Study does not adequately consider the characteristics of the site with respect to its established uses, built form and recognitions as previously developed land. This is demonstrated through the Parcel Assessments included in the Green Belt Study, with the promoted land included incorrectly within Parcel 21 alongside undeveloped farmland. The parcel sizes identified through the study vary considerably in
shape and size, with specific characteristics of land informing the parcel sizes. An example of this and the resulting assessment of Green Belt factors is Parcel P29 that covers the land off Rayleigh Down Road and The Drive, where residential buildings and area of external caravan storage alongside/ horticultural/agricultural buildings have been recognised within a smaller parcel area and assessed as having less contribution to
Green Belt as a result. This approach of applying a smaller parcel should also have been identifeid for the land at Lower Wyburns Farm, which would have enabled its assessment separately from the woodland, playing fields and pasture that makes up the rest of parcel
21 to the east. The Green Belt Study undertaken has therefore not allowed for the appropriate assessment of edge of settlement sites that would otherwise be considered as sustainable allocation options and be taken forward for further consideration through the
Local Plan process.
7.5. The reduced openness and lack of rural character afforded by the existing structures on site reduces the land’s contribution to the Green Belt considerably. In accordance with the principles established by the Joint Green Belt Study, alongside the reduced contribution of
the land to the purposes of the Green Belt, the highly sustainable location of the site adjacent to Rayleigh and the accessibility of local services and facilities from the site, should also ensure that the land at Lower Wyburns Farm is identified as a suitable candidate for Green Belt release.

Q56b. With reference to Figure 44 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses?
How could that improve the completeness of Rayleigh?
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community Infrastructure [open space, education, healthcare, allotments, other]
4. Other

8.2. Promoted sites CFS068 and CFS069 (Land at Lower Wyburns Farm) identified on Figure 44 should be made available for residential development. Although land at Lower Wyburns Farm promoted by Southern and Regional Developments is not identified on the walking completeness score map presented within the ‘Complete Communities’ Topic Paper, the site is located adjacent to areas afforded attributed a walking completeness score of 8-10 showing that reasonable levels of services and facilities are located within the ‘walking catchment’ of the land. Notwithstanding this, it is recommended that the
Council be pragmatic in applying walking completeness scores where the Topic Paper confirms that being located outside of the comfortable walking catchment for a specific facility does not mean that the facility is inaccessible. This assertion is particularly relevant
for Rayleigh, where the Topic Paper establishes that 56% of the settlement is located within the walking catchment of a frequent bus service. A review of the promoted land’s context confirms that the site is located within a 5 minute walk from existing bus stops sited along the Eastwood Road. These bus stops provide very frequent services to a range of destinations including, Southend-on-Sea, Shoeburyness, Rayleigh, and Basildon Town
Centre. As such, Claremont Planning recommend that the Council recognises the highly sustainable location of the promoted land at Lower Wyburns Farm for residential
development, given both the variety of services and facilities located within the land’s walking catchment, and the site’s close proximity to frequent public transport services.
8.3. Moreover, the vision for Rayleigh advanced by the Consultation Document sets out the ambition to provide for a diverse range of housing which meet the needs of all in the community. The 2017 Strategic Housing Market Assessment (SHMA) establishes that both within Rochford, and across the South Essex region, the greatest additional demand for housing will be generated by households requiring family housing with three bedrooms. As such, it is considered that the release of the land at Lower Wyburns Farm from the Green Belt, and its allocation for residential development can strongly contribute to delivering housing to meet this need where greenfield land is considered to be more appropriate for
the delivery of family-sized housing. It is also advised that the Authority acknowledge the strategic location of the land at Lower Wyburns Farm in close proximity to the District boundary and connection to the A127 as a location which may be appropriate to meet any unmet need for family housing arising from the wider South Essex region.
8.4. It has been established that Rayleigh benefits from high levels of completeness, with a large percentage of the settlement located within the walking catchment of education, sport, leisure, and health facilities however, the ‘Complete Communities Topic Paper’ identifies that only 18% of Rayleigh is located within the walking catchment of green infrastructure. Previous representations made to the Authority promoting the land at Lower Wyburns Farm have identified that the site’s development will include provision of an area of public open space to the north west of the site. As such, it is considered that the allocation of the site will both continue to ensure that development at Rayleigh is located in the most sustainable locations, that are areas within the walking catchment of a good range of services and facilities, whilst also seeking to address deficiencies in green infrastructure provision in Rayleigh.
Enclosed: Site Location Plan: Lower Wyburns Farm, Daws Heath Road, Rayleigh
:Dwg SK001 Illustrative Masterplan

ROCHFORD NEW LOCAL PLAN: SPATIAL OPTIONS CONSULTATION- SUBMISSION OF REPRESENTATIONS ON BEHALF OF SOUTHERN & REGIONAL DEVELOPMENTS LIMITED
Claremont Planning Consultancy have been instructed by Southern and Regional Developments Limited to prepare and submit representations to the new Local Plan: Spatial Options consultation.
Southern and Regional Developments are in control of two sites within the Rochford District; the land at Lower Wyburns Farm, Rayleigh, and Sutton Road, Rochford, with both sites previously promoted to the Council through the 2018 Call for Sites exercise for the emerging
Local Plan. For clarity, it has therefore been considered prudent to prepare and submit representations to the Spatial Options consultation separately considering each site separately.
As such, please find the following sets of representations enclosed:
• Lower Wyburns Farm representations to Spatial Options- Location Plan and Illustrative
Masterplan enclosed.
• Sutton Road representations to Spatial Options - Location Plan enclosed
We trust that these representations are clear and will be duly taken into consideration, however, if Southern and Regional Developments or Claremont Planning can assist with providing any further information in relation to the sites at Lower Wyburns Farm and Sutton Road, or the content of the representations submitted, please do not hesitate to contact me on the details below.

Rochford District Council – Lower Wyburns Farm, Rayleigh
Representations to the Spatial Options
1. Introduction
1.1. On behalf of Southern and Regional Developments Ltd, Claremont Planning Consultancy has been instructed to prepare and submit representations to the Spatial Options consultation being undertaken by Rochford District Council to inform the emerging Local
Plan.

2. Strategy Options
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?

2.1. Claremont Planning, on behalf of Southern and Regional Development’s Ltd, are supportive of the settlement hierarchy proposed. The identification of Rayleigh as the only ‘Tier 1’ settlement within the District is supported, finding this proportionate to the settlement’s larger population and comprehensive service base, which is of both local and regional prominence. The proposed settlement hierarchy correctly recognises the strategic location of Rayleigh which affords the settlement a functional relationship with the adjacent
Southend, Basildon, Chelmsford, and London Districts.
2.2. It is recommended that the spatial strategy advanced by the emerging Local Plan be strongly informed by the proposed settlement hierarchy. The proposed hierarchy of settlements evidences that Rayleigh benefits from a wide range of retail, employment, and community facilities and therefore represents a highly sustainable location for development. In accordance with the provisions of Paragraph 16 of the National Planning
Policy Framework (NPPF), development plans should be prepared with the objective of contributing to the achievement of sustainable development. As such, it is advisable that the overall distribution of growth is informed by this imperative, and a larger quantum of
growth apportioned to those settlements which are identified by the hierarchy as being most sustainable, chiefly Rayleigh. To accommodate the necessary growth of Rayleigh a full review of the settlement boundary should be undertaken through this plan review process, with Green Belt release of suitable sites promoted to ensure that Rayleigh can accommodate the level of growth its position in the settlement hierarchy requires.

Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
Strategy Option 1: Urban Intensification
2.3. It is advised that Strategy Option 1: Urban Intensification is not advanced on its own. The current standard method identifies a housing requirement of 7,200 dwellings for the district across the next 20 years, however the consultation document establishes that only 4,500 new dwellings can be delivered through Option 1. Paragraph 35 of the NPPF identifies that Plans must provide a strategy which as a minimum seeks to meet the area’s objectively assessed needs in order to be found sound. Delivering development through Strategy Option 1 will result in a substantial shortfall in housing delivery and will unlikely be considered sound by the Inspector when the Plan is examined.
Strategy Option 2: Urban Extensions
2.4. It is recognised that Strategy Option 2, which seeks to spread development across several development sites of between 10 and 1,500 homes adjoining existing towns and villages, could deliver a sustainable distribution of housing growth. The dispersal of urban extensions based on the settlement hierarchy is supported, where this would see growth delivered at the most sustainable settlements in the District. In accordance with the proposed settlement hierarchy, the allocation of urban extensions at Rayleigh, the District’s largest and most sustainable settlement, should be prioritised if this option is taken forward. When considering urban extensions, they should not prohibit the appropriate review of a settlement’s boundary and site releases from the Green Belt for development elsewhere. Co-ordinating urban extensions that are typically large scale developments
alongside smaller site allocations will facilitate the delivery of small to medium sites as advised by the NPPF at Paragraph 69; which will enable the continual supply of housing through a maintained trajectory.
Strategy Option 3: Concentrated Growth
2.5. Concentrating growth in one or more locations of 1,500+ dwellings, as promoted within Strategy Option 3 is not supported on its own at this time. Large allocations and the development of new settlements, by virtue of their complexity and infrastructure requirements, have much longer lead in times for delivery and therefore would be likely to contribute towards meeting housing needs towards the end of the Plan period and beyond.
As such, pursuit of this Strategy Option alone will not deliver sufficient housing to meet the Authority’s housing needs in the earlier years of the Plan, leaving the Authority vulnerable to speculative development which is not Plan lead particularly if delays in the delivery of
these allocations arise. Topic Paper 9: Housing prepared in support of the Spatial Options Consultation 2021 illustrates that over the last 10 years Rochford’s historic rate of housing delivery is 227 dwellings per annum, requiring an uplift of around 60% in annual housing
completions to meet the local housing need identified for the new Local Plan. The Authority should note that paragraph 69 of the NPPF advises against the concentration of growth as proposed within Strategy Option 3, instead recommending that development plans should seek to accommodate at least 10% of their housing requirement on sites no larger than one hectare. Given the uplift in housing delivery which will be required to meet housing need, it would be prudent that the Council also consider the allocation of small and
medium sized sites, such as the promoted land at Lower Wyburns Farm, which can contribute directly to the next 5 year supply and be delivered quickly, making a more
immediate contribution to housing supply alongside this Strategy.
Strategy Option 4: Balanced Combination
2.6. Strategy Option 4 advances a balanced combination of the various Strategy Options presented, including making the best use of urban capacity (Option 1), building on one or two large growth areas (Option 3), and a number of smaller urban extensions (Option 2).
Claremont Planning strongly recommend that the Authority pursue the blended approach promoted within Option 4. It is considered that Option 4 represents the most sustainable means of meeting the District’s housing requirement, by maximising sites available within the existing urban area, and delivering smaller urban extensions at sustainable locations in accordance with the proposed settlement hierarchy. Paragraph 69 of the NPPF establishes that a blended approach which allocates small, medium, and larger sites for development is advisable, ensuring that any potential delays in the delivery of larger allocations do not
adversely affect housing delivery in the District.
2.7. Paragraph 35 of the NPPF sets out the tests for ‘soundness’ of development plans, establishing that plans should, as a minimum, seek to meet their areas objectively assessed housing need and be informed by agreements with other authorities so that any unmet need from neighbouring areas can be accommodated where it is practical to do so. The southern and northern parcels of the land promoted by Southern and Regional
Developments at Lower Wyburns Farm have been recognised by the Council within their Site Assessment Paper 2021, with references CFS068 and CFS069 respectively; for their potential to deliver growth through Option 2, small urban extensions. Claremont Planning
strongly support the Council’s recognition of the land’s potential and note that the land occupies a highly sustainable location adjacent to the District’s only Tier 1 settlement.
Furthermore, the promoted site should be recognised as a suitable location which could contribute towards unmet need arising from neighbouring authorities due to its close geographical proximity to adjacent districts, particularly to the Castle Point Borough and
Southend-on-Sea Districts, whilst also benefitting from a close functional relationship these due to its proximity to the strategic highway network, namely the A127.

3. Spatial Themes
Q9. Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and
coastal change wherever possible? How can we best protect current and future communities from flood risk and coastal change?

3.1. National policy, chiefly paragraph 161 of the NPPF, is clear in its expectations that development plans apply a sequential, risk-based approach to the location of development which includes taking into account all sources of flood risk as well as current and future
impacts of climate change. As such, it is agreed that a sequential approach to flood risk and coastal change should be adopted by the Plan, and this would be a sound approach that is consistent with national planning policy. As recognised by the Council, much of the
District is affected by Flood Zone 3 with flood risk likely to be subject to coastal change as a result of climate change. As such, it is recommended that development opportunities within areas at lower risk of flooding are fully considered by the Authority. Approaching flood risk and coastal change sequentially would also accord with the proposed settlement hierarchy, concentrating development at the main settlements of the District, including Rayleigh which are the areas within the District at lower risk of flooding.
3.2. The land at Lower Wyburns Farm, Daws Heath Road represents one such suitable location for development if the sequential approach to flood risk is adopted. With respect to the parcel of land south of Daws Heath Road, only a very small area along Daws Heath Road, is affected by Flood Zone 2. With respect to the promoted parcel of land north of the road, this is more heavily influenced by flood risk, being completely covered by Flood Zones 2 and 3. Previous representations submitted to the Council through the SHLAA/Call for Sites process by Claremont Planning have considered the flood risk present on the site at length and it is advanced that the flood zone 3 areas should be removed from consideration for development and instead contribute toward public open space provision and ecological enhancement measures. Any development on the northern parcel should be focused upon redeveloping the existing dwelling on the site, away from the flood prone
areas and towards the frontage with Daws Heath Road.
3.3. When assessing the flood risk of the promoted land at Lower Wyburns Farm within their initial site assessments, the Council also recognise that the majority of the promoted land is at low risk of flooding, scoring the northern and southern parcels of the site as 3 and 4 respectively for flood risk on a scale on for which 5 represents the best performing sites.
Given that the vast majority of the promoted land at Lower Wyburns Farm south of Daws Heath Road is located within Flood Zone 1, and the Council’s recognition that the site performs strongly in respect of flood risk; Claremont Planning consider that the
development of this land would be in accordance with the recommended sequential approach to flood risk in the Plan.

4. Housing for All
Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes, and tenures of housing?

4.1. Meeting the need for different types, sizes, and tenures of housing by requiring a suitable or negotiable mix of housing that is responsive to the type and location of development, as promoted by Option 2, is recommended by Claremont Planning. It is considered that this represents the most pragmatic approach to meeting these needs by providing flexibility in the market to ensure that the right types of homes are delivered in the right locations. Applying a blanket housing mix policy would fail to recognise that some types of land are
more well suited to certain forms of development. For example, both the Housing Topic Paper 2021 and 2017 SHMA establish that there is the greatest need for small and midsized semi-detached and detached dwellings. Claremont Planning consider that the release of Green Belt land, including the site at Lower Wyburns Farm should be strongly considered by the Council whereby the release of this land will both assist the Council in
meeting their overall housing need and facilitate the delivery of an appropriate mix of housing. In particular this will assist delivery of family sized housing which is better suited to delivery on greenfield land than constrained urban sites.

5. Green and Blue Infrastructure
Q32. With reference to the options above, or your own options, how do you feel we can best deliver quality green and blue infrastructure network throughout the Plan?
5.1. The Green and Blue Infrastructure Topic Paper 2021 identifies that previous housing and economic growth throughout South Essex has not been sufficient to meet the region’s growth potential. As such, Claremont Planning maintain that although delivering quality
green and blue infrastructure is valuable, this must be balanced against the region’s need for growth. It is therefore recommended that identifying general objectives for strategic green and blue infrastructure through the plan (Option 2) is pursued by the Authority, with this Option relying on other existing allocations, such as open space, local green space, and local wildlife site designations to deliver improvements. The suggestion identified within the Topic Paper that the Plan could still contain policies that help to deliver improvements to green and blue infrastructure, including the capture of funding through planning obligations associated with development is recommended to be advanced
alongside this approach. Advancing Option 2 would continue to promote the delivery of improvements on site where appropriate, without constraining the ability of development to make the most effective use on land by requiring on-site improvements to be delivered.
Moreover, it is not considered that detailed, site-specific policies are relevant for inclusion within a strategic plan of this nature where national planning policy establishes in Chapter 3 of the NPPF the role that strategic policies should play, which is to set the overall strategies for the pattern, scale and design quality of places. As such, policies relating to site specific provision of green and blue infrastructure would be more appropriately dealt
with through the preparation non-strategic level Plans and Policies such as those in Neighbourhood Plans.
5.2. The Green and Blue Infrastructure Topic Paper 2021 also establishes that the connectivity of green and blue infrastructure is challenging, with many poor green and blue linkages between towns, villages, rural areas and waterfronts. Whilst Option 3, requiring certain new
developments to provide local green and blue infrastructure on-site, may increase the quantum of green and blue infrastructure throughout Rochford, there is risk that this may worsen the connectivity of these spaces through their piecemeal development.
Contrastingly, securing funding through planning obligations as part of Option 2 could deliver strategic improvements to this network to be made in accordance with a wider vision for the area. This would represent a more effective and deliverable strategy, meeting that criteria for soundness as identified in the NPPF.

6. Town Centres and Retail
Q46. With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley?
How can we also ensure our village and neighbourhood centres remain vibrant?
6.1. Claremont Planning support the ambition of Options 5 and 10 in their recognition that delivering a suitable mix of uses including residential development is essential in
continuing to support the vitality and viability of town centres. It is considered important however, that the Council recognise the importance of allowing settlements to expand through new development outside of the existing settlement boundary, as this can allow the population of settlements to grow. This in turn can increase footfall to existing shops and services, and enhance the vitality and viability of these settlements, especially where good pedestrian connectivity to the town centre is present. Whilst it is recognised that the
consultation document identifies that town centres within the District have not suffered declines in footfall as acutely as national trends would indicate, further development and growth at a settlement could ensure that town centres remain sustainable in the future.

7. Green Belt and Rural Issues – Plan Objective 20 (p.69-70)
7.1. The recognition that the release of Green Belt land will be required to meet housing needs through the emerging Plan is strongly supported. It is agreed that the Council can demonstrate the exceptional circumstances necessary to justify this release, in accordance with paragraph 141 of the NPPF. The Consultation Document has sought to establish that a spatial strategy reliant on urban intensification will not deliver sufficient housing to meet the Council’s objectively assessed need and confirms that early discussions with adjacent authorities has not identified capacity for accommodating unmet need arising from Rochford. As such, it is agreed and supported that the emerging Local Plan will be able to
demonstrate the exceptional circumstances necessary to justify the release of Green Belt land.
7.2. The Rochford District and Southend-on-Sea Joint Green Belt Study (February 2020) forming the evidence base to this consultation contains detailed site assessments that identify the contribution made by promoted sites to the purposes of the Green Belt. Within
this report, the land at Lower Wyburns Farm was assessed as making a strong contribution to the purposes of the Green Belt, finding that the site presents a strong openness and has a closer relationship with the surrounding countryside than the urban area. Likewise, the initial assessment proformas prepared by the Authority also rated the identified site as relatively strongly performing Green Belt. These conclusions are refuted and it is considered that these assessments failed to recognise several key features of the promoted land which diminish its contribution to the Green Belt. Notably, assessments of the land around the site have failed to identify that both the north and south parcels of the site are currently in use and developed; with the original farmhouse and livery stables in the southern parcel alongside a range of buildings and yards that accommodate B2 Industrial uses with external storage areas and further Sui Generis horticultural and
residential uses located within the northern parcel. As such, a large quantum of the promoted site’s area represents previously developed land and should be prioritised for development.
7.3. The Joint Green Belt Study however establishes that the environmental and sustainability effects of development need to be considered when releasing land from the Green Belt, where it may be that the most sustainable locations for development may not be
appropriate or sustainable, with this pragmatic approach to Green Belt release strongly supported by Claremont Planning where it accords with the provisions of paragraph 142 of the NPPF. Specifically, paragraph 142 of the Framework recommends that plans should give first consideration to land which is previously developed and/or well served by public transport when considering Green Belt release. It has been established that a proportion of the land promoted by Southern and Regional Developments at Lower Wyburns Farm
represents previously developed land, as previously recognised in the Council’s 2017 SHELAA assessment of the southern parcel (CFS068), with built form existing on the southern parcel of the site in particular with a variety of B2 industrial sheds alongside an established concrete hardstanding and occupied by structures extending up to two stories in height, obscuring any view of the wider countryside and significantly reducing the land’s openness. Moreover, the industrial units occupying the land at present host a variety of established uses, including a lawn mower repair shop and vehicle servicing, alongside a camping and caravan site, whilst the northern parcel of land is used as a plant nursery. As
such, both parcels benefit from established activity and transport movements further reducing openness characteristics attributed to the site.
7.4. At present the Green Belt Study does not adequately consider the characteristics of the site with respect to its established uses, built form and recognitions as previously developed land. This is demonstrated through the Parcel Assessments included in the Green Belt Study, with the promoted land included incorrectly within Parcel 21 alongside undeveloped farmland. The parcel sizes identified through the study vary considerably in
shape and size, with specific characteristics of land informing the parcel sizes. An example of this and the resulting assessment of Green Belt factors is Parcel P29 that covers the land off Rayleigh Down Road and The Drive, where residential buildings and area of external caravan storage alongside/ horticultural/agricultural buildings have been recognised within a smaller parcel area and assessed as having less contribution to
Green Belt as a result. This approach of applying a smaller parcel should also have been identifeid for the land at Lower Wyburns Farm, which would have enabled its assessment separately from the woodland, playing fields and pasture that makes up the rest of parcel
21 to the east. The Green Belt Study undertaken has therefore not allowed for the appropriate assessment of edge of settlement sites that would otherwise be considered as sustainable allocation options and be taken forward for further consideration through the
Local Plan process.
7.5. The reduced openness and lack of rural character afforded by the existing structures on site reduces the land’s contribution to the Green Belt considerably. In accordance with the principles established by the Joint Green Belt Study, alongside the reduced contribution of
the land to the purposes of the Green Belt, the highly sustainable location of the site adjacent to Rayleigh and the accessibility of local services and facilities from the site, should also ensure that the land at Lower Wyburns Farm is identified as a suitable candidate for Green Belt release.

Q56b. With reference to Figure 44 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses?
How could that improve the completeness of Rayleigh?
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community Infrastructure [open space, education, healthcare, allotments, other]
4. Other

8.2. Promoted sites CFS068 and CFS069 (Land at Lower Wyburns Farm) identified on Figure 44 should be made available for residential development. Although land at Lower Wyburns Farm promoted by Southern and Regional Developments is not identified on the walking completeness score map presented within the ‘Complete Communities’ Topic Paper, the site is located adjacent to areas afforded attributed a walking completeness score of 8-10 showing that reasonable levels of services and facilities are located within the ‘walking catchment’ of the land. Notwithstanding this, it is recommended that the
Council be pragmatic in applying walking completeness scores where the Topic Paper confirms that being located outside of the comfortable walking catchment for a specific facility does not mean that the facility is inaccessible. This assertion is particularly relevant
for Rayleigh, where the Topic Paper establishes that 56% of the settlement is located within the walking catchment of a frequent bus service. A review of the promoted land’s context confirms that the site is located within a 5 minute walk from existing bus stops sited along the Eastwood Road. These bus stops provide very frequent services to a range of destinations including, Southend-on-Sea, Shoeburyness, Rayleigh, and Basildon Town
Centre. As such, Claremont Planning recommend that the Council recognises the highly sustainable location of the promoted land at Lower Wyburns Farm for residential
development, given both the variety of services and facilities located within the land’s walking catchment, and the site’s close proximity to frequent public transport services.
8.3. Moreover, the vision for Rayleigh advanced by the Consultation Document sets out the ambition to provide for a diverse range of housing which meet the needs of all in the community. The 2017 Strategic Housing Market Assessment (SHMA) establishes that both within Rochford, and across the South Essex region, the greatest additional demand for housing will be generated by households requiring family housing with three bedrooms. As such, it is considered that the release of the land at Lower Wyburns Farm from the Green Belt, and its allocation for residential development can strongly contribute to delivering housing to meet this need where greenfield land is considered to be more appropriate for
the delivery of family-sized housing. It is also advised that the Authority acknowledge the strategic location of the land at Lower Wyburns Farm in close proximity to the District boundary and connection to the A127 as a location which may be appropriate to meet any unmet need for family housing arising from the wider South Essex region.
8.4. It has been established that Rayleigh benefits from high levels of completeness, with a large percentage of the settlement located within the walking catchment of education, sport, leisure, and health facilities however, the ‘Complete Communities Topic Paper’ identifies that only 18% of Rayleigh is located within the walking catchment of green infrastructure. Previous representations made to the Authority promoting the land at Lower Wyburns Farm have identified that the site’s development will include provision of an area of public open space to the north west of the site. As such, it is considered that the allocation of the site will both continue to ensure that development at Rayleigh is located in the most sustainable locations, that are areas within the walking catchment of a good range of services and facilities, whilst also seeking to address deficiencies in green infrastructure provision in Rayleigh.
Enclosed: Site Location Plan: Lower Wyburns Farm, Daws Heath Road, Rayleigh
:Dwg SK001 Illustrative Masterplan

Rochford District Council – Land to the north of Sutton Road, Rochford
Representations to the Spatial Options Consultation
1. Introduction
1.1. On behalf of Southern and Regional Developments Ltd, Claremont Planning Consultancy has been instructed to prepare and submit representations to the Spatial Options consultation being undertaken by Rochford District Council to inform the emerging Local Plan.

Strategy Options
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?
1.2. Claremont Planning on behalf of Southern and Regional Development’s Ltd are generally supportive of the settlement hierarchy proposed. Rochford is identified as a ‘Tier 2’ settlement within the hierarchy recognising the settlement’s sizeable population and comprehensive local service base. Whilst it is acknowledged that Rochford has a considerably smaller population than
that of Rayleigh, meriting its location below Rayleigh within the settlement hierarchy; the placement of Hockley and Rochford within the same ‘Tier’ in the hierarchy is disputed. Although the populations are of a similar size, the proposed settlement hierarchy fails to account for the
strategic location of Rochford adjacent to London Southend Airport. The close proximity of Rochford to the airport provides the settlement with key transport infrastructure which connects Rochford to the wider South Essex region and rest of the country. As such, it is considered that Rochford should be distinguished from Hockley within the proposed settlement hierarchy by
virtue of its local and nationally strategic location.
1.3. It is recommended that the spatial strategy advanced by the emerging Local Plan be strongly informed by the proposed settlement hierarchy In accordance with the provisions of Paragraph 16 of the National Planning Policy Framework (NPPF), development plans should be prepared with the objective of contributing to the achievement of sustainable development. As such, it is
advisable that the overall distribution of growth is informed by this imperative and larger quantum of growth apportioned to those settlements which are identified by the hierarchy as being most sustainable. The proposed settlement hierarchy acknowledges the sustainability of Rochford for development, whilst these representations have also sought to illustrate the strategic location of
the settlement due to the presence of the London Southend Airport and its planned continued expansion to provide additional employment floorspace and associated employment opportunities.

Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?

Strategy Option 1: Urban Intensification
1.4. It is advised that Strategy Option 1: Urban Intensification is not advanced. The current standard
method identifies a housing requirement of 7,200 dwellings in the district across the next 20 years however the consultation document establishes that approximately only 4,500 new dwellings can be delivered through Option 1. Paragraph 35 of the NPPF identifies that Plans must provide a strategy which as a minimum seeks to meet the area’s objectively assessed needs in order to be found sound. Delivering development through Strategy Option 1 will result in a substantial shortfall in housing delivery and will unlikely be considered sound by the Inspector when the Plan is examined.
Strategy Option 2: Urban Extensions
1.5. It is recognised that Strategy Option 2, which seeks to spread development across a number of development sites of between 10 and 1,500 homes adjoining existing towns and villages, could deliver a sustainable distribution of housing growth. The dispersal of urban extensions based on the settlement hierarchy is supported, where this would therefore see the largest quantum of growth apportioned to the most sustainable settlement settlements within the District as established by the proposed settlement hierarchy and it is therefore recommended that growth at sustainable settlements such as Rayleigh and Rochford should be prioritised if this option is taken forward.
1.6. Moreover, the land north of Sutton Road at Rochford as promoted by Southern and Regional Developments, has been identified within the initial appraisal undertaken by the Council as making a potential contribution to Strategy Option 2. It is agreed that the promoted land off Sutton Road could make an effective contribution to the delivery of this Strategy Option where the land abuts established areas of residential development at the settlement and is located in close proximity to employment opportunities at the Purdeys Industrial Estate. As such, the land at Sutton Road is considered to represent a logical location for the further expansion of Rochford should Option 2 be advanced by the Authority.
Strategy Option 3: Concentrated Growth
1.7. Concentrating growth in one or more locations of 1,500+ dwellings, as promoted within Strategy Option 3 is not supported. Large allocations and the development of new settlements, by virtue of their complexity and infrastructure requirements, have much longer lead-in times for delivery and therefore would be likely to contribute towards meeting housing needs towards the end of the Plan period and beyond. As such, pursuit of this Strategy Option alone will not deliver sufficient housing to meet the Authority’s housing needs in the earlier years of the Plan, leaving the Authority vulnerable to speculative development which is not Plan lead particularly if delays in the delivery of these allocations arise. Topic Paper 9: Housing prepared in support of the
Spatial Options Consultation 2021 illustrates that over the last 10 years Rochford’s historic rate of housing delivery is 227 dwellings per annum, requiring an uplift of around 60% in annual housing completions to meet the local housing need identified for the new Local Plan. The
Authority should note that paragraph 69 of the NPPF advises against the concentration of growth as proposed within Strategy Option 3, instead recommending that development plans should seek to accommodate at least 10% of their housing requirement on sites no larger than one hectare. Given the uplift in housing delivery which will be required to meet housing need, it would be prudent that the Council also consider allocating sites of a variety of sizes which can be builtout relatively quickly and make a more immediate contribution to housing supply.
Strategy Option 4: Balanced Combination
1.8. Strategy Option 4 advances a balanced combination of the various Strategy Options presented, including making the best use of urban capacity (Option 1), building on one or two large growth areas (Option 3), and a number of smaller urban extensions (Option 2). Claremont Planning strongly recommend that the Authority pursue the blended approach promoted within Option 4. It is considered that Option 4 represents the most sustainable means of meeting the District’s
housing requirement, by maximising sites available within the existing urban area, and delivering smaller urban extensions at sustainable locations in accordance with the proposed settlement hierarchy. Paragraph 69 of the NPPF establishes that a blended approach which allocates small, medium, and larger sites for development is advisable, ensuring that any potential delays in the delivery of larger allocations do not adversely affect housing delivery in the District.
1.9. Paragraph 35 of the NPPF sets out the tests for ‘soundness’ of development plans, establishing
that plans should, as a minimum, seek to meet their areas objectively assessed housing need and be informed by agreements with other authorities so that any unmet need from neighbouring areas can be accommodated where it is practical to do so. As established, the land at Sutton Road as promoted by Southern and Regional Developments has been assessed by the Council under reference CFS067 within their 2021 Site Appraisal Paper prepared in support the Spatial Options consultation. Within this assessment, the land at Sutton Road is positively considered by the Authority and its availability and deliverability for residential development recognised.
Moreover, Claremont Planning assert that the Council should recognise that the land at Sutton Road performed strongly through this assessment in relation a wide variety of criteria including but not limited to flood risk; landscape harm; site hazards and conditions; and access to facilities and services. As such, the land at Sutton Road should be strongly considered for allocation
through the emerging Local Plan, given both its environmental, and social sustainability.

2. Spatial Themes
Q9. Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and coastal change wherever possible? How can we best protect current and future communities from flood
risk and coastal change?

2.1. National policy, chiefly paragraph 161 of the NPPF is clear in its expectations that development plans apply a sequential, risk-based approach to the location of development which includes taking into account all sources of flood risk as well as current and future impacts of climate change. As such, it is agreed that a sequential approach to flood risk and coastal change should be adopted by the Plan, and this would be a sound approach that is consistent with national planning policy. As recognised by the Council, much of the District is influenced by high flood risk that is likely to be subject to coastal change as a result of climate change. As such, it is recommended that development opportunities within areas at lower risk of flooding are fully considered by the Authority. Approaching flood risk and coastal change sequentially would also accord with the proposed settlement hierarchy, concentrating development at the main settlements of the District, including Rochford and Rayleigh which are the areas within the District
at lower risk of flooding.
2.2. The land at Sutton Road promoted by Southern and Regional Developments represents a suitable location for development if the sequential approach to flood risk is adopted. Although an inappreciable area to the extreme south east of the land is located within Flood Zone 3, the
Environment Agency’s flood map for planning identifies that this area of the site also benefits from flood defences; whilst the rest of the land promotion is located within Flood Zone 1, being at low probability of flooding. 2.3. Within the 2021 Site Appraisal Paper, the Council identified that the promoted land at Sutton Road performs very strongly in relation to flood risk, recognising that this small area of flood risk on site is not detrimental to the land’s deliverability. The pragmatic approach advanced by the Council in relation to flood risk on site is therefore supported. Moreover, any development scheme proposed on the site would be designed such to sensitively respond to the risk of flooding on site, through the promotion of this area as public open space. This would ensure that flood
risk on site can be suitably accommodated whilst also enhancing the quality of any development scheme pursued through the provision of high quality public open space. Given that the vast majority of the promoted land at Sutton Road is sited within Flood Zone 1, alongside the Council’s recognition that the site performs strongly in respect of flood risk, Claremont Planning consider that the development of this land would be in accordance with the recommend sequential approach to flood risk in the Plan.

3. Housing for All
Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes, and tenures of housing?

3.1. Meeting the need for different types, sizes, tenures of housing by requiring a suitable or negotiable mix of housing that is responsive to the type and location of development, as promoted by Option 2 is recommended by Claremont Planning. It is considered that this represents the most pragmatic approach to meeting these needs by providing flexibility in the market to ensure that the right types of homes are delivered in the right locations. Applying a blanket housing mix policy would fail to recognise that some types of land are more well suited to certain forms of development. For example, both the Housing Topic Paper 2021 and 2017 SHMA establish that there is the greatest need for small and mid-sized semi-detached and detached dwellings.
Claremont Planning consider that the release of Green Belt land, including the promoted land off Sutton Road should be strongly considered by the Council whereby the release of this land will both assist the Council in meeting their overall housing need, and facilitate the delivery of an appropriate mix of housing. In particular this will assist the delivery of family sized housing which
is better suited to delivery on greenfield land than constrained urban sites.

4. Future of London Southend Airport
Q28. With reference to the options listed above, or your own opinions, how do you feel we can best manage the Aiport’s adaptations and growth through the planning system?
[please state reasoning].

4.1. Following the adoption of the current Joint Area Action Plan for the London Southend Airport in 2014, the context for the Airport’s future growth has altered substantially. The consultation document establishes that the Airport’s development will need to respond to the emerging Government Aviation Strategy. Moreover, the COVID-19 pandemic has substantially impacted the Airport, with planned growth now envisaged to take place over a much longer time period than initially anticipated. Claremont Planning therefore agree that it is prudent to prepare an updated Joint Area Action Plan which accounts for both the changed policy, and economic
context of the Airport’s growth.
4.2. The regional importance of the airport, alongside its strategic cross-boundary location within Southend but adjacent to Rochford necessitates that a joint approach for the Airport’s growth is advanced in accordance with a coherent vision. Although Option 2 would satisfy the need for a joint, cross boundary approach to the Airport’s growth, national policy is clear that strategic policies should be focussed on setting overall strategies for the pattern scale and design. As such, development at London Southend Airport would more appropriately be considered within a detailed Area Action Plan rather than through Local Planning Policy. As such, Claremont
Planning would support the pursuit of Option 4, where this Option will ensure that any resultant Area Action Plan can be prepared in accordance with policies contained within the new Local Plan.

5. Green and Blue Infrastructure
Q32. With reference to the options above, or your own options, how do you feel we can best deliver quality green and blue infrastructure network throughout the Plan?
5.1. The Green and Blue Infrastructure Topic Paper 2021 identifies that previous housing and economic growth throughout South Essex has not been sufficient to meet the region’s growth potential. As such, Claremont Planning maintain that although delivering quality green and blue infrastructure is valuable to the wellbeing of Rochford residents, this must be balanced against
the region’s need for growth. It is therefore recommended that identifying general objectives for
strategic green and blue infrastructure (Option 2) is pursued by the Authority, with this Option relying on other existing allocations, such as open space, local green space, and local wildlife site designations to deliver improvements.
5.2. The suggestion identified within the Topic Paper that the Plan could still contain policies that help to deliver improvements to green and blue infrastructure, including the capture of funding through planning obligations associated with development is recommended to be advanced alongside this approach. Advancing Option 2 would continue to promote the delivery of improvements on site where appropriate, without constraining the ability of development to make the most effective use on land by requiring on site improvements to be delivered. Moreover, it is not considered that detailed, site-specific policies are relevant for inclusion within a strategic plan of this nature where national planning policy established in Chapter 3 of the Framework the role those strategic
policies should play, which is to set out the overall strategies for the pattern, scale and design quality of such places. As such, policies relating to the site specific provision of green and blue infrastructure would be more appropriately dealt with through the preparation of non-strategic level Plans and Policies, such as those in Neighbourhood Plans.
5.3. The Green and Blue Infrastructure Topic Paper 2021 also establishes that the connectivity of green and blue infrastructure is challenging, with many poor green and blue linkages between towns, villages, rural areas, and waterfronts. Whilst Option 3, requiring certain new developments to provide local green and blue infrastructure on-site, may increase the quantum of green and blue infrastructure throughout Rochford, there is risk that this may worsen the connectivity of these spaces through their piecemeal development. Contrastingly, securing funding through planning obligations as part of Option 2 could deliver strategic improvements to this network to be made in accordance with a wider vision for the area. This would represent a more effective and deliverable strategy in meeting that criteria for soundness as identified in the NPPF.

6. Town Centres and Retail
Q46. With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh, and Hockley? How can we ensure our village and neighbourhood centres remain vibrant?

6.1. Claremont Planning support the ambition of Options 5 and 10 in their recognition that delivering a suitable mix of uses including residential development is essential in continuing to support the viability and vitality of town centres. It is considered important however, that the Council recognise the important of allowing settlements to expand through new development outside of the existing settlement boundary, as this can allow the population of settlements to grow. This in turn can
increase footfall to existing shops and services, and enhance the vitality and viability of these settlements, especially where good pedestrian connectivity to the town centre is present. Whilst it is recognised that the consultation document identifies that town centres within the District have not suffered declines in footfall as acutely as national trends would indicate, further development could ensure that town centres remain sustainable in the future.

7. Green Belt and Rural Issues – Plan Objective 20 (p.69-70)
7.1. The recognition that the release of Green Belt land will be required to meet housing needs through the emerging Plan is strongly supported. It is agreed that the Council can demonstrate the exceptional circumstances necessary to justify this release, in accordance with paragraph 141 of the NPPF. The Consultation Document has sought to establish that a spatial strategy reliant on urban intensification will not deliver sufficient housing to meet the Council’s objectively assessed need, and confirms that early discussions with adjacent authorities have not identified capacity for accommodating unmet need arising from Rochford. As such, it is agreed that the
emerging Local Plan will be able to demonstrate the exceptional circumstances necessary to justify the release of Green Belt land.
7.2. The Rochford District and Southend-on-Sea Joint Green Belt Study (February 2020) supporting this consultation contains detailed site assessments of the contribution made by promoted sites to the purposes of the Green Belt, including an assessment of the promoted land north of Sutton Road at Rochford that is within a wider Parcel 63. The assessment of the land presented within the Green Belt study is supported, where the assessment recognises the diminished contribution
made by the site to the purposes of the Green Belt, particularly safeguarding the countryside from encroachment and preventing coalescence, by virtue of the site’s relative enclosure by the established Rochford settlement. When the harm of the Parcel’s release was assessed at Stage 2 of the Study, it was concluded that moderate harm to the Green Belt would result. Claremont
Planning contest this conclusion, and assert that instead the harm resulting from the Parcel’s release is instead low, or low-moderate. The Stage 2 assessment undertaken recognises that this parcel of land is weaker performing Green Belt due to its high level of containment, going on to establish that by virtue of this containment the release of land in this area would be of no harm to adjacent Green Belt parcels. Due to the recognition within this assessment that the release of
this land from the Green Belt would not be detrimental to the wider Green Belt, the subsequent conclusion that moderate harm to the Green Belt would result, is not considered to be robustly justified.
7.3. National planning policy, chiefly paragraph 142 of the NPPF, sets out that where exceptional circumstances are demonstrated, a pragmatic approach to Green Belt release, giving first consideration to land which is previously developed and/or well-served by public transport, should be advanced. Claremont Planning support the assertion made within the Joint Green Belt
Study paper that the environmental and sustainability effects of Green Belt release need to be considered alongside the harm to the Green Belt of release, where the most sustainable locations for development may not be the areas which would result in the least harm to the Green Belt. Where this nuanced approach to Green Belt release is considered, Claremont Planning contend
that the merits of releasing the promoted land off Sutton Road are especially evident where it has been established that the site represents a both a highly sustainable location for development at one of the District’s main settlements, and a location at which harm to the Green Belt arising from the land’s release is limited. In light of both the limited contribution made to the Green Belt by this parcel, alongside the negligible harm arising from the land’s release and highly sustainable location, it is strongly recommended that the Council consider the promoted land at Sutton Road
for Green Belt release.

8. Planning for Complete Communities
Q57a. Do you agree with our vision for Rochford and Ashingdon? Is there anything you
feel is missing?
8.1. The proposed vision statement for Rochford and Ashingdon is generally supported by Claremont
Planning, where it proposes the further growth and development of the settlement. In particular, the vision statement’s recognition of the settlement’s strategic location close to key employment sites and London Southend Airport, and intention to bolster its regionally significant role is strongly supported. However, it is considered that the proposed vision statement places too great an emphasis on economic growth at the settlement. Instead, Claremont Planning recommend
that the proposed vision statement be amended to include a more balanced and holistic approach
to growth, where it is considered that the Council should recognise the role that residential development has in supporting both the vitality and viability of town centres, alongside a recognition that economic and jobs growth must be supported by sufficient housing provision to
support the local workforce. Moreover, as a ‘Tier 2’ settlement in the District, Rochford represents a highly sustainable location for residential development and should therefore represent a location for significant growth through the emerging Local Plan to assist in meeting the District’s housing needs. As such, it is advised that the vision statement be revised to recognise the role of residential, alongside economic development in realising the growth ambitions of the district.
Q57b. With reference to Figure 45 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Rochford and Ashingdon?
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community Infrastructure [open space, education, healthcare, allotments, other]
4. Other
8.2. Promoted site CFS067 as identified on Figure 45: Map of Rochford and Ashingdon, should be made available for residential development. Through these representations to the Spatial Options consultation, Claremont Planning have sought to identify that the central location of the promoted land at Sutton Road within the Rochford settlement establishes the land as both a highly sustainable, and logical location for further residential development. This assertion is complemented by the 2021 Complete Communities Topic Paper prepared by the Authority within with the promoted land is located within an area identified as having a high walking completeness score of 11-13, meaning that there are a large number of services and facilities located within walking distance of the site. However, the Complete Communities Topic Paper also identifies that whilst the most complete areas in the settlement are located near the town centre, there are areas of low population density in and around the centre where future growth might optimise proximity to services. As established, the land off Sutton Road is entirely enclosed by the established Rochford settlement, and abuts existing residential development and employment
land at all elevations. Given the high walking completeness score of the land, the development
of the site represents an opportunity to both locate development at the most sustainable locations
within the settlement, whilst increasing the number of residents living in ‘complete’ areas.
8.3. The Complete Communities Topic Paper demonstrates that Rochford has good levels of
completeness in respect of access to education, health, civic, and sport and leisure facilities whilst only 8% of the settlement is located within the walking catchment of green infrastructure. It is considered that the release of the promoted land off Sutton Road for residential development represents an opportunity to address this shortfall. Within the south of the site at Sutton Road is
a small area of Flood Zone 3 which is promoted for use as public open space / access arrangements through any development proposal advanced. Moreover, the north-easternmost corner of the land is located within the Southend Airport Public Safety Zone within which
development potential is restricted. As such, this area is also promoted for and provides an opportunity to deliver public open space and ecological enhancement. Through careful scheme design it is therefore considered that any proposed development on site will deliver a connected series of public open spaces and green infrastructure, supporting both recreational activities and
delivering biodiversity gains. Given the relative enclosure of the site by established development, it is considered that both future occupants and residents of the wider site area will benefit from this enhanced green infrastructure provision.
Enclosed : Site Location Plan