New Local Plan: Spatial Options Document 2021

The publication of the Spatial Options Consultation document is a welcome step forward for the new Local Plan. Although notionally the adopted Core Strategy covers the period to 2025, that document is now a decade old, and it is important therefore for the Council to move forward and get a new Local Plan in place. Not only are some of the key assumptions in the Core Strategy regarding housing requirements and employment provision now substantially out of date, but there is in any event only a limited period of time now until the end date of the Core Strategy is reached, and it is important for the sustainable management of future development and its co-ordination with the necessary infrastructure for a long-term replacement Plan to be brought in to place as soon as practically possible.

We appreciate that the original intention had been for the new Local Plan to be guided by the Joint South Essex Plan, and of course that may still be the case, and that process may raise additional strategic options for consideration. However, in the absence of the joint strategic plan, we support the Council in moving forward at this stage with a range of strategic options for consultation, in light of the urgent need for progress outlined above.

It would be helpful to provide clarity on the period that the new Local Plan is intending to cover. The Committee Report and Vision section refer to the Plan setting out a 30 year vision for the District at 2050 (which coincides with the period for the joint Strategic Plan). However, the growth strategy section refers to growth requirements over the next 20 years. The different time spans are confusing, plus it is difficult to explain how the vision for 2050 would be achieved if the Plan is only delivering growth to the 2040s.

We agree with the settlement hierarchy as illustrated in Figure 13 and as explained in the supporting text.
In addition to the range of facilities and services referred to for Rayleigh, we would also add that the town has the benefit of high quality public transport opportunities, with a comprehensive bus network and the railway station. Whilst Rochford and Hockley also provide good rail and bus services, the strategic location of Rayleigh on the western side of the district, rather than the east side, offers the greatest opportunities for the use of public transport for access to the so-called Tier 0 settlements such as Basildon, Chelmsford and London.

We support the use of the standard methodology figure of 360 homes per annum as a sensible premise upon which the growth options are based.

On that basis, the Lower Growth Scenario of 4,500 homes appears to be effectively a ‘marker’ only rather than a realistic scenario, as the negative implications of not providing enough homes in terms of affordability and need are well explained in the document, and there is no substantive rationale put forward as to why less than the standard methodology could be justified in the case of Rochford district (as Green Belt of itself would not be sufficient justification, particularly in light of the disadvantages of this approach as stated).

The document rightly explains that delivering transformational infrastructure essentially requires larger scale growth. Given the disparity between the Vision end date and the growth scenario end date, a further option that therefore warrants consideration in terms of how best to manage growth and deliver substantive new infrastructure is for the Plan to cover the longer time period to 2050 i.e. the higher growth figure of 10,800 could be justified either because of the economic and housing benefits (as per the graphic on page 28), or because by looking to plan over the longer timeframe, it creates more opportunities to deliver the larger types of new infrastructure referred to in the table on page 28.

In terms of the strategic options, Strategy Option 1 (Urban Intensification) is effectively a part of all of the options, and therefore with the exception of the first bullet point under “pros +” for this option (no release of Green Belt land), the other positives listed actually apply in all of the other scenarios as well. As the benefit of the first bullet point is more than off-set by the negatives listed and the fact that it is not a feasible strategy for a sound Plan anyway, Strategy Option 1 can effectively be discarded as it is only a sub-element of the other strategies, rather than a strategy in its own right.

In order to avoid confusion, it would be helpful if the next iteration of the Plan could explain that Strategy Option 1 is not an option in its own right, but will form a sub-element of all options going forward.

As currently worded, it is unclear as to what the actual implications are of increasing development within the existing urban areas. The text refers to a figure of 1500 new homes arising from the Urban Capacity Study, which appears to include an assumption relating to higher densities, whilst the table acknowledges that higher densities could have negative impacts on local character because of the fact that most of the existing towns are built at what might loosely be referred to as suburban densities. In order to understand the implications of delivering 1500 units, it would be helpful for the consultation document to explain what this figure means in terms of assumed densities and house types, compared to what exists already, as without that context, it is difficult for the reader to appreciate what increasing urban densities actually means, and what the implications might be (including what standards the Council might consider need relaxing in order to achieve higher densities). It would also be helpful to explain what figure the Council consider could be achieved from urban capacity if all existing standards (parking, garden areas etc) are maintained, and if densities are limited to typical existing densities.

The key issue with Strategy Option 2 (Urban Extensions) is that a reliance only on smaller scale urban extensions at the expense of larger strategic sites is likely to make strategic-scale infrastructure less deliverable. We recognise that this is referred to in the pros and cons analysis, but the first bullet points under “pros +” for this option is not sufficiently clear on the difficulties of delivering substantive infrastructure from a myriad of different sites in different locations, not just in terms of the lost funding from sites that come in under infrastructure thresholds or where existing capacity justifies no contributions at all for smaller sites, but also the issue of securing land for new infrastructure projects, where no individual site may be of sufficient scale to deliver land for infrastructure and housing. In essence, Strategic Option 2 is the ‘worst of both worlds’ option as far as local residents would perceive it – the growth occurs but without the necessary infrastructure.

If Strategic Option 3 (Concentrated Growth) were progressed on the basis of maximising infrastructure delivery from a single strategic site, then Option 3a (west of Rayleigh) presents clear advantages over Options 3b and 3c, both because of the position of Rayleigh in the settlement hierarchy, and because of the relative location of growth west of Rayleigh and its ability to interconnect with adjoining regional centres at Chelmsford and Basildon. As we have noted above, Rayleigh is the most sustainable settlement for expansion, is strategically the best placed, and is subject to the least constraints (for example in terms of agricultural land quality, wildlife designations, access to the strategic highway network, and other environmental designations). Strategic growth at Southend reinforces the pressure on the urban infrastructure in and around Southend, and in particular places further pressure on the arterial road links, whereas strategic growth west of Rochford would see growth concentrated at a lower order centre without the wider facilities and infrastructure to support it.

A key issue for Strategic Option 3, which is hinted at in the ‘Cons’ section but is not explicit, is the long lead in time for the largest strategic sites. Not only do they raise more complex issues of infrastructure co-ordination (the Council will no doubt be aware that the last two Plans in Essex to be found unsound both depended on complex infrastructure proposals where delivery couldn’t be properly evidenced), but the lead-in time itself for delivery could also cause difficulties for the Council in maintaining an appropriate land supply for the short and medium terms.

Strategic Option 4 (Balanced Combination) is largely a continuation of the existing Core Strategy approach to the distribution and scale of development. It combines the positive aspects of all of the previous options, but we would also note the additional positive aspects that should be added to the list of “Pros”, being:
• As an extension of the existing Core Strategy approach of balanced growth, this approach has previously been held to be sound, deliverable, and sustainable, through testing at Examination in the past.
• It is an approach that has proved to be successful – whilst the pace of growth may differ slightly from the original trajectory, by and large, the strategy of balanced growth has been successfully implemented, and the relevant infrastructure to support the scale of development envisaged in the Core Strategy has been secured. The balanced growth approach therefore has a proven track record.

With the above in mind, we would query the “Cons” that have been listed against this approach.

With regard to the first bullet point, this strategy is no more complex in terms of the co-ordination of infrastructure than the existing Core Strategy, and infrastructure has been successfully secured even where this transcends individual sites (an example being the securing of the improvements to the Rawreth Lane/Hullbridge Road/Hambro Hill junction through co-ordinated delivery from the Hullbridge and Rayleigh allocations).

In terms of risk of delivery (the second bullet point), all of the major allocations under the existing Core Strategy are progressing, and therefore there is no evidence of substantive risk.

In terms of the third bullet point, any release of land from the Green Belt of the scale envisaged under Options 2, 3 and 4 will be noticeable, and there is no reason to suppose that a smaller number of larger Green Belt releases is any more harmful to the perceived openness of the Green Belt than multiple smaller changes. Far greater weight should be placed on the ability of Strategy Option 4 to provide a portfolio of sites of different size, that will be important for delivery.

In relation to the final bullet point in the list of ‘Cons’ for Strategy Option 4, one of the advantages of this option compared to dispersed growth is that it better allows for impact on services to be managed. Settlements do change character when they grow, but that change need not be harmful if it is well managed, and the quality of new development is good.

On the basis of the above, we do not consider that any of the “cons” listed against Option 4 really stand up to substantive scrutiny. Whilst Option 3 has merits in terms of delivery of large scale growth and infrastructure, Option 4 offers a significant number of benefits and no substantive disbenefits, and has the significant additional benefits of being tried and tested.

Conclusion on Growth Scenarios

In summary therefore, Strategy Option 1 is not a strategy in its own right, and it would be helpful if future consultations could make this clear. It would also assist understanding if the potential impacts of higher density could be explained and quantified.

Strategy Option 2 essentially relates to a very wide dispersal of growth across the district, which will not only create significant issues in terms of infrastructure delivery, but will also lead to a highly unsustainable pattern of development in terms of travel movements and maximising access to public transport and locating development close to the main facilities and services. Whilst elements of Option 2 will no doubt be important in terms of providing a range of deliverable sites that serves the needs of the larger settlements, this Option in isolation does not deliver the same benefits as Option 4.

Strategy Option 3 is higher risk and likely to lead to delayed delivery due to the scale of the strategic sites envisaged, but if this option were pursued, Option 3a has clear advantages over Options 3b and 3c, due to the locational advantages of Rayleigh, the relative environmental constraints, and the likely impacts.

Strategy Option 4 is essentially a continuation of the existing, successful Core Strategy, which has proven to be deliverable, has proven to be capable of delivering co-ordinated infrastructure, and which delivers a balanced portfolio of strategic sites alongside other smaller scale opportunities both within and adjoining the main towns.

We therefore strongly support Option 4.

The document lists a number of potential options by which the accommodation needs of gypsies and travellers may be met, including through a specific ‘call for sites’ exercise (which would allow members of these communities to put their own sites forward for allocation), through expansion of existing sites and authorisation of some existing unauthorised sites, and through the Michelin Farm proposal. We agree that a combination of these options is likely to be appropriate.

However, we do not support the provision of gypsy and travellers sites as part of new strategic residential allocations (option 6) – this is because integrating gypsy and traveller provision within major new residential development tends not to satisfy either the settled or the travelling communities. As Rochford District has other options that are likely to be more appropriate for the gypsy and traveller community, preference should be given to these.

The document lists a number of potential options by which the accommodation needs of gypsies and travellers may be met, including through a specific ‘call for sites’ exercise (which would allow members of these communities to put their own sites forward for allocation), through expansion of existing sites and authorisation of some existing unauthorised sites, and through the Michelin Farm proposal. We agree that a combination of these options is likely to be appropriate.

However, we do not support the provision of gypsy and travellers sites as part of new strategic residential allocations (option 6) – this is because integrating gypsy and traveller provision within major new residential development tends not to satisfy either the settled or the travelling communities. As Rochford District has other options that are likely to be more appropriate for the gypsy and traveller community, preference should be given to these.

1.0 Introduction
1.1 These representations are submitted to the Rochford New Local Plan Spatial Options (RLPSO) on behalf of Countryside Properties and in respect of Land at Pulpits Farm, Hockley.
1.2 The Site has previously been submitted in response to the Council’s Call for Sites, and is reference CFS263 in the Council’s plan-making process (although also referred to as Site 272, in the Council’s Green Belt Study (2020))
1.3 This representation should be read alongside the Vision Document that has been prepared in respect of the development of the Site, and which accompanies the
representations as Appendix A.
2.0 Response to Local Plan Spatial Options Question 4
Q4. Do you agree with the strategic priorities and objectives we have identifies? Is there anything missing from the strategic priorities or objectives that you feel
needs to be included?
2.1 We suggest that improving the affordability of housing for local people in Rochford District should form an objective of the Local Plan.
2.2 As the RLPSO rightly recognises at page 12, housing affordability is a particularly issue within the District.
2.3 ONS data on the affordability of housing reports that in 2020 the median house price was 11.57 times the median gross annual workplace-based earnings. The affordability of housing has worsened significantly in recent years, and is substantially worse than the
national average.
2.4 Without an increase in housing supply, we consider there is a very real risk that it will only worsen.
2.5 Not only do current projections suggest increased housing need in the District, but the longer term impact of the Covid-19 pandemic may well place additional pressure on Rochford’s housing market and affordability of homes for local people.
2.6 Early indications are that there has already been an increased desire to move from more to less urban areas, due to a combination of a desire for homes with larger garden areas and home offices, better access to open space, and within less densely populated areas; and people considering it less critical to live very near their place of work, given the increase in home working within a number of employment sectors.
2.7 This is of particular relevance to Rochford District, given that London is accessible via railway services from parts of the District; and house prices are relatively affordable when compared to other areas in and around London.
3.0 Response to Local Plan Spatial Options Question 6
Which of the identified strategy options do you consider should be taken forward in the Plan?
3.1 We consider that a balanced approach that includes direction of a relatively significant proportion of the District’s housing needs to the higher tier settlements (including Hockley) would be the most appropriate strategy, for the reason set out below.
Strategy Option 1 – Urban Intensification
3.2 The RLPSO states that this option would entail making best possible use of our existing planned developments, previously developed land and other under-utilised land, such as vacant buildings and contaminated land; and notes that a strategy based on urban intensification could also include taking a more permissive approach to higher densities in suitable locations (such as town centres and near stations). It is suggested this would involve no loss of Green Belt land, would minimise loss of greenfield, and would deliver
4,200 homes over the next 10 years.
3.3 The RLPSO describes Strategy Option 1 as “the minimum expectation of national policy” and states it is “likely to be required within every strategy option”.
3.4 We agree that it would be consistent with national policy to seek to promote the redevelopment of appropriate previously developed land to help meet development needs. However, we consider that a strategy which were to rely purely on this to meet development needs would be ineffective, unsustainable, incapable of meeting development needs in full as required by national policy, and result in a Local Plan that would be inherently unsound.
3.5 The National Planning Policy Framework (NPPF) confirms (paragraph 35) that one of the requirements of a sound Local Plan is that it seeks to meet the area’s objectively assessed development needs in full. The NPPF also emphasises the Government’s objective to significantly boost housing land supply (paragraph 60).
3.6 However, the RLPSO acknowledges that Strategy Option 1 would fall significantly short of meeting local development needs in full. Not only would this render the plan unsound and contrary to the NPPF, but it would likely result in significant negative social and economic impacts locally.
3.7 In any case, we consider that a yield of 4,200 dwellings over 10 years through urban intensification to be unfeasibly optimistic.
3.8 To achieve this quantum, it would be necessary to sustain an average of 420 dwellings per annum (dpa) over a 10-year period. The Council’s Annual Monitoring Report 2019/20 states that between April 2010 and March 2020, the District achieved a total of 1,768 dwelling completions over this particular 10-year period – an average of just 177 dpa. Furthermore, the delivery of these 1,768 dwellings was not solely through urban
intensification, but also included allocations made through the Rochford Allocations Plan (2014). There is of course only a finite supply of previously developed land that is
suitable and viable for residential redevelopment, and it is considered that much of this has likely already been exhausted, particularly given the emphasis placed by national and local policy on utilising such sites.
3.9 In addition to Strategy Option 1 being unlikely to deliver anywhere near the number of new homes needed in the District, we would also question the appropriateness of such a strategy in any case. To make a meaningful contribution to housing needs over the
plan period, this strategy would likely require development at a significantly greater density than existing development in the District. Not only could this be harmful to the character of the District’s residential areas, but it may also result in loss of amenity for existing residents.
3.10 Furthermore, it is unclear if this approach would deliver the types of homes required where they are required in the District. Such a strategy is, for example, unlikely to deliver a high proportion of family homes.
3.11 For the above reasons, we do not consider that Strategy Option 1 is capable of resulting in a sound Local Plan and should be discounted.
Strategy Options 2, 3 and 4
3.12 Given Strategy Option 1’s inability to result in a sound Local Plan, this leaves Options 2, 3 and 4 as potential strategies.
3.13 Strategy Option 2 is to focus on urban extensions, with Option 2a entailing focussing such growth on the District’s main towns; and Option 2b dispersing to all settlements based on the settlement hierarchy.
3.14 Through Strategy Option 2 sustainable sites could be utilised at the edge of settlements, which should include Hockley, to deliver a range of housing developments, including the provision of much needed housing in the short term. This option provides flexibility to utilise smaller sites to deliver homes earlier alongside larger sites to meet the overall housing need.
3.15 We consider that Strategy Option 2b should include growth to Hockley, given that it is a top tier settlement in the adopted Development Plan’s settlement hierarchy.
3.16 In relation to Option 3, this suggests focussing growth on one of three locations (west of Rayleigh (3a); north of Southend (3b); and east of Rochford (3c)). We consider there is merit to strategic scale growth that can help deliver significant infrastructure improvements. However, this needs to be complemented by the delivery of a range of different sites (including those that can deliver in the short term and do not require
significant infrastructure improvements) and in a range of different locations that reflect the fact that the District comprises a number of distinct settlements with their own
identities and communities, all of which the Local Plan should seek to support.
3.17 The outcome of the Uttlesford Local Plan Examination provdes a warning regarding the dangers of over reliance on large strategic growth sites to meet housing needs. Recommending the submitted plan be withdrawn due to soundness issues, the Inspectors concluded:
“In order to arrive at a sound strategy, we consider that as a primary consideration, the Council would need to allocate more small and medium sized sites that could
deliver homes in the short to medium term and help to bolster the 5 year [housing land supply], until the Garden Communities begin to deliver housing. This would have
the benefit of providing flexibility and choice in the market and the earlier provision of more affordable housing”. (Paragraph 114 of Uttlesford Local Plan Examination
Inspectors’ letter of 10 January 2020)
3.18 This does not of course mean that the strategy cannot include strategic growth allocations, only that if it were to, they would need to be accompanied by a range of other small and medium sized sites.
3.19 Strategy Option 4 entails a mix of the other options, and rightly recognises that the alloction of strategic growth sites and the allocation of urban extensions are not mutually exclusive. We consider this option does have particular merit, and it is notable that it was scored positively by the Integrated Impact Assessment (IIA) in relation to its social, economic and environmental impacts. This option will still allow for current housing
needs to be addressed in the short term, as the Local Plan is required to; as well as enabling provision of strategic allocations if so wished. It will also allow for proportionate growth to be directed to the District’s various communities through settlement extensions, including Hockley – something which we consider is essential for the Local Plan to do if it is to deliver sustainable development.
Hockley
3.20 We consider that, in order for the Local Plan’s spatial strategy to promote sustainable development, to be justified, and to be capable of being found sound, it will be essential for it to direct a proportion of the District’s growth to Hockley.
3.21 Hockley / Hawkwell is identified as a Tier 1 settlement in the current Development Plan, i.e. one of the settlements considered most sustainable to accommodate greatest levels of growth.
3.22 Notwithstanding this, the District has experienced considerably less housing development since adoption of the Core Strategy than the other two Tier 1 settlements.
It is recognised that this is in part due to aspirations for the redevelopment of the town centre not being realised, as conditions have changed; and also partly due to constraints to the settlement’s growth as a result of Hockley Woods and the Upper Roach Valley Special Landscape Area to the south. Nevertheless, there are opportunities to deliver sustainable extensions to the existing settlement, particularly located away from the
more sensitive areas to the south.
3.23 Hockley is an established, vibrant community with a long history. It is important that planning helps support and enhance the vitality of the community, including by directing future growth to the settlement.
3.24 The RLPSO recognises that housing affordability and availability are key issues in Hockley. The Local Plan represents an opportunity to help address this issue, by
directing additional housing to this location. Conversely, failure to direct sufficient housing to Hockley is likely to result in housing becoming increasingly unaffordable for
local people. It is manifestly clear that if the Local Plan is to be a sound plan that meets development needs in a sustainable manner, then it cannot rely on RLPSO Option 1.
Alterations to the Green Belt boundary
3.25 It is evident that the District’s Green Belt boundaries will need to be amended in order to meet development needs and provide a sound plan for the future of the District.
3.26 The NPPF confirms (paragraph 140) that Local Plans are the appropriate vehicle through which to make alterations to the Green Belt boundary.
3.27 The NPPF (paragraph 140 again) also states that such alterations should only be made where exceptional circumstances are fully evidenced and justified.
3.28 Exceptional circumstances are not defined in national policy or guidance.
3.29 However, there is case law which provides a basis for the consideration of the issue. In particular, the judgment in Calverton Parish Council v Nottingham City Council & Ors [2015] EWHC 1078 (Admin) suggests (paragraph 51) that the following matters are relevant in the consideration of whether exceptional circumstances exist to justify alterations to the Green Belt:
 The scale of the objectively assessed need;
 Constraints on supply/availability of land with the potential to accommodate sustainable development;
 Difficulties in achieving sustainable development without impinging on the Green Belt;
 The nature and extent of the harm to the Green Belt; and  The extent to which impacts on the purposes of the Green Belt may be mitigated as far as practicable.
3.30 The District is subject to an acute local housing need. The existing Green Belt boundary
is drawn tightly around the District’s existing settlements, and opportunities to meet development needs are severely restricted without alterations to the Green Belt
boundary.
3.31 Given the scale of objectively assessed need faced by the District, and the lack of potential alternatives to releasing Green Belt in order to sustainably meet such needs, it is evident that there are exceptional circumstances that justify alteration to the Green
Belt through the Rochford Local Plan.
4.0 Response to Local Plan Spatial Options Question 29
Do you agree that the plan should designate and protect areas of land of locally important wildlife value as a local wildlife site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection?
4.1 We agree that the Local Plan should seek to protect areas of locally important wildlife. Furthermore, we consider it should seek to deliver ecological gains.
4.2 However, the designation of such sites must be justified by robust evidence.
4.3 The 2018 Local Wildlife Review suggested a new Local Wildlife Site (R41) which
incorporates some of what is currently Local Wildlife Site R24, along with additional land to the west of this, including part of the Land at Pulpits Farm (CFS263 (‘the Site’).
4.4 The evidence for designating such additional land as a Local Wildlife Site is unclear.
4.5 It is not clear from the 2018 Local Wildlife Site Review what particular characteristics of the land forming part of CFS263 proposed to be designated as a Local Wildlife Site justify this land’s designation as such.
4.6 There is no evidence that a detailed survey of the Site was undertaken as part of the 2018 Local Wildlife Site Review that could justify its inclusion within a Local Wildlife Site.
4.7 The Site has been subject to an ecological constraints and opportunities survey, undertaken in 2020 by qualified specialist ecological consultancy, Southern Ecological Solutions.
4.8 This survey identified that the Site comprises habitats of varying value to biodiversity, with the most suitable habitat at the Site’s boundaries in the form of hedgerows, mature trees, rough grassland margins and watercourses. However, there was nothing to suggest that the Site merits any form of designation for its ecological value.
4.9 A copy of this initial survey is provided as Appendix B to these representations.
4.10 It is not the case that evidence must be provided to set out why the Site should not form part of the Local Wildlife Site. On the contrary, if this land is to be designated as a Local Wildlife Site, it is incumbent upon the Council to provide robust evidence justifying this.
4.11 We do not consider the Site merits designation for its ecological value, and would object to any proposals to do so. However, we do recognise that parts of the Site are of
ecological value. As part of the development of the Site, existing ecological features would be retained and, where practicable, enhanced.
4.12 It is important to recognise that development of land often has the potential to engender ecological benefits, and that would be the case in the development of site CFS263.
5.0 Response to Local Plan Spatial Options Question 58
Q58a. Do you agree with our vision for Hockley and Hawkwell? Is there anything you feel is missing?
5.1 We agree with the vision for Hockley as proposed by the RLPSO.
5.2 In particular, we very much support the objective of improving housing affordability in order to ensure that local first-time buyers can afford to live locally.
5.3 If this vision is to be realised, it will be imperative to provide a sufficient number of new homes for Hockley, and of a variety of types and tenures, to meet all of the community’s needs.
Q58b. With reference to Figure 46 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 Hockley and Hawkwell?
i. Housing
5.4 Land at Pulpits Farm (CFS263, ‘the Site’) is suitable, available, and achievable for residential development as a sustainable extension to Hockley. The Vision Document
which accompanies this representation (Appendix A) sets out details regarding the Site’s ability to sustainably deliver a high-quality development.
5.5 The Site was considered through the Council’s Strategic Housing Land Availability Assessment (SHELAA) (2020). The SHELAA (2020) considered the Site’s suitability in relation to a multitude of constraints, including policy, environmental, ecological, heritage
and physical constraints. In respect of the Site and potential constraints, this assessment concluded:
“Green Belt site that is currently in mixed use with residential and ancillary outbuildings, with some vacant grassland. There is an existing access with no
fundamental constraints to redevelopment of the site” [Emphasis added].
5.6 In summary, the only constraint to the Site’s development identified was its location within the Green Belt in the current Development Plan – a policy constraint.
5.7 In addition, the SHELAA (2020) assessed the Site’s suitability in terms of its accessibility to local services.
5.8 In relation to accessibility alone, it stated:
“There are two bus stops within c 0.3km of the site, however these are served by only two bus routes (No7/18). A private road connects the site to Greensward Lane, a C road which traverses the centre of Hockley before connecting to the wider strategic road network”
5.9 In addition to the points made within the SHELAA (2020) we would add that the Site is c.12 minutes walking distance from Hockley railway station. When considering
accessibility of this Site, and its appropriateness for allocation, this is clearly a key consideration.
5.10 In particular, it is important to note that the NPPF instructs Local Planning Authorities to prioritise sites that have good access to public transport when considering release of Green Belt to meet development needs. At paragraph 142 of the NPPF it states:
“Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previouslydeveloped and/or is well-served by public transport”.
5.11 The Green Belt is drawn tightly around the existing extent of residential development in Hockley. As noted in our response to Question 6, Hockley is clearly a sustainable location to accommodate a proportion of the District’s housing needs, and furthermore it is important that the vitality of Hockley be supported through the direction of sustainable growth to the settlement. It will be necessary to direct some growth to Hockley in order to ensure a sound Local Plan that delivers sustainable development, and to deliver this it will be necessary to alter the existing Green Belt boundary. In making such a revision, sites such as CFS263 which have good access to public transport should be prioritised for residential allocation.
5.12 The SHELAA (2020) considered the Site’s proximity to local services and stated: “A primary school sits c 1km to the east of the site, with a secondary school c 0.6km
to the west. A garden centres [sic] sits within C 0.3km of the site with a small number of shops along Greensward Lane”.
5.13 We consider the above significantly understates the range of local services and facilities that are in proximity to the Site.
5.14 In particular, the SHELAA (2020) appears to have overlooked that the Site is adjacent to
a GP surgery.
5.15 The Site is also well located in relation to a range of other services, facilities, employment opportunities and centres. As set out in the Vision Document that accompanies this representation, the following can be reached without use of a car within the following
journey times:
Walking:
Bus stop 1 minute
Greensward Surgery 1 minute
Greensward Academy Secondary School 5 minutes
Hockley Railway Station 12 minutes
Plumberow Academy Primary School 15 minutes
Convenience retail (Co-Op, Spa Road) 15 minutes
Hockley Post Office 15 minutes
Eldon Way 15 minutes
Approximate centre of Hockley Town Centre 17 minutes
Bus:
Approximate centre of Hockley Town Centre 5 minutes
Rochford Town Centre 14 minutes
Rayleigh Town Centre 16 minutes
Train:
Southend Victoria 27 minutes
London Liverpool Street 60 minutes
5.16 In 2014, sustainable transport charity Sustrans estimated that school traffic contributed,
nationally, to 24% of all traffic at peak times. The accessibility of both primary and
secondary schools from the Site without reliance on a car, and the potential to avoid
additional traffic that might be otherwise generated, is considered to be a factor which
weighs significantly in favour of utilising this Site to help meet housing needs.
5.17 The principal constraint to the Site’s development is that it is currently within the Green Belt.
5.18 In terms of the Site’s contribution to the purposes of the Green Belt, it is relevant to note that is an edge-of-settlement Site, the character of which has been influenced by adjacent residential uses to the north, west and south. The Site is subject to a degree of containment provided by existing features, and its development would not give rise to unrestricted urban sprawl. On the contrary, it would allow for a new, robust Green Belt
boundary to be implemented.
5.19 The Council’s Rochford District and Southend-on-Sea Borough Joint Green Belt Study February 2020 (‘the Green Belt Study (2020)’ concluded that the western portion of the Site could be developed with only moderate harm to the Green Belt. This is before mitigation measures are factored in (which case law suggests must be considered in determining whether exceptional circumstances apply), and once potential measures are
accounted for (such as provision of landscape buffers) it is considered that the Site’s development would not undermine the strategic purposes of the Green Belt.
5.20 Use of the Site to provide market and affordable homes would result in a number of social, economic and environmental benefits, as set out within the Vision Document
(Appendix A). These include, in summary:
 Market and affordable homes to help meet acute local need;
 Highly accessible Site, with opportunities for future residents to access services and facilities without use of a car;
 Efficient use of land which lacks environmental constraints, reducing pressure to develop more sensitive sites to meet needs;
 Provision of variety of public open space across the Site, including informal open space, ponds, structural landscaping for wildlife;
Increased expenditure within the local area, supporting jobs and helping sustain local facilities and services;
 Creation of direct employment during construction, as well as indirect employment related to the supply chain;
 Landscape and ecological enhancements as part of development;
 Development within a location that will help sustain the vitality of Hockley Town Centre.
5.21 It is important that where Green Belt is released for housing, the Council can have confidence that such land will be delivered and contribute to meeting needs.
5.22 In addition to being suitable and sustainable, the Site is also available and achievable for residential development.
5.23 The Site is not subject to any legal or ownership constraints to development.
5.24 The Site is being actively promoted for development by an established housebuilder with a track record of delivery. The Council can be confident that the Site will be deliver, and through a high-quality development, if allocated through the Local Plan.
6.0 Comments on Integrated Impact Assessment
Assessment Framework
6.1 At Table 1.1 of the Integrated Impact Assessment (IIA), the assessment framework is set out. This explains that the objectives of the population and communities theme are
1) to cater for existing and future residents’ needs as well as the needs of different groups in the community; and 2) maintain and enhance community and settlement identity.
6.2 In respective of objective 1, Table 1.1 explains that assessment questions relate to the following:
 Meet the identified objectively assessed housing needs, including affordable, for the plan area?
 Ensure an appropriate mix of dwelling sizes, types and tenures to meet the needs of all sectors of the community?
 Improve cross-boundary links between communities?
 Provide housing in sustainable locations that allow easy access to a range of local services and facilities?
 Promote the development of a range of high quality, accessible community facilities, including specialist services for disabled and older people?
6.3 We support the above decision-aiding question, but suggest that, in addition to meeting the District’s housing needs (including affordable housing), the Local Plan should seek to improve the affordability of housing for local residents.
6.4 The median house price in the District is 11.57 times the median gross annual workplacebased earnings (‘the affordability ratio’). The affordability of housing has worsened significantly in recent years – and to a much greater extent than the national average. In 2000, the affordability ratio for the District was 5.08 – only slightly worse than the national average of 4.13. By 2020, the national affordability ratio had increased to 7.69 –
significantly below the District’s 11.57.

1.0 Introduction
1.1 These representations are submitted to the Rochford New Local Plan Spatial Options (RLPSO) on behalf of Countryside Properties and in respect of Land at Pulpits Farm, Hockley.
1.2 The Site has previously been submitted in response to the Council’s Call for Sites, and is reference CFS263 in the Council’s plan-making process (although also referred to as Site 272, in the Council’s Green Belt Study (2020))
1.3 This representation should be read alongside the Vision Document that has been prepared in respect of the development of the Site, and which accompanies the
representations as Appendix A.
2.0 Response to Local Plan Spatial Options Question 4
Q4. Do you agree with the strategic priorities and objectives we have identifies? Is there anything missing from the strategic priorities or objectives that you feel
needs to be included?
2.1 We suggest that improving the affordability of housing for local people in Rochford District should form an objective of the Local Plan.
2.2 As the RLPSO rightly recognises at page 12, housing affordability is a particularly issue within the District.
2.3 ONS data on the affordability of housing reports that in 2020 the median house price was 11.57 times the median gross annual workplace-based earnings. The affordability of housing has worsened significantly in recent years, and is substantially worse than the
national average.
2.4 Without an increase in housing supply, we consider there is a very real risk that it will only worsen.
2.5 Not only do current projections suggest increased housing need in the District, but the longer term impact of the Covid-19 pandemic may well place additional pressure on Rochford’s housing market and affordability of homes for local people.
2.6 Early indications are that there has already been an increased desire to move from more to less urban areas, due to a combination of a desire for homes with larger garden areas and home offices, better access to open space, and within less densely populated areas; and people considering it less critical to live very near their place of work, given the increase in home working within a number of employment sectors.
2.7 This is of particular relevance to Rochford District, given that London is accessible via railway services from parts of the District; and house prices are relatively affordable when compared to other areas in and around London.
3.0 Response to Local Plan Spatial Options Question 6
Which of the identified strategy options do you consider should be taken forward in the Plan?
3.1 We consider that a balanced approach that includes direction of a relatively significant proportion of the District’s housing needs to the higher tier settlements (including Hockley) would be the most appropriate strategy, for the reason set out below.
Strategy Option 1 – Urban Intensification
3.2 The RLPSO states that this option would entail making best possible use of our existing planned developments, previously developed land and other under-utilised land, such as vacant buildings and contaminated land; and notes that a strategy based on urban intensification could also include taking a more permissive approach to higher densities in suitable locations (such as town centres and near stations). It is suggested this would involve no loss of Green Belt land, would minimise loss of greenfield, and would deliver
4,200 homes over the next 10 years.
3.3 The RLPSO describes Strategy Option 1 as “the minimum expectation of national policy” and states it is “likely to be required within every strategy option”.
3.4 We agree that it would be consistent with national policy to seek to promote the redevelopment of appropriate previously developed land to help meet development needs. However, we consider that a strategy which were to rely purely on this to meet development needs would be ineffective, unsustainable, incapable of meeting development needs in full as required by national policy, and result in a Local Plan that would be inherently unsound.
3.5 The National Planning Policy Framework (NPPF) confirms (paragraph 35) that one of the requirements of a sound Local Plan is that it seeks to meet the area’s objectively assessed development needs in full. The NPPF also emphasises the Government’s objective to significantly boost housing land supply (paragraph 60).
3.6 However, the RLPSO acknowledges that Strategy Option 1 would fall significantly short of meeting local development needs in full. Not only would this render the plan unsound and contrary to the NPPF, but it would likely result in significant negative social and economic impacts locally.
3.7 In any case, we consider that a yield of 4,200 dwellings over 10 years through urban intensification to be unfeasibly optimistic.
3.8 To achieve this quantum, it would be necessary to sustain an average of 420 dwellings per annum (dpa) over a 10-year period. The Council’s Annual Monitoring Report 2019/20 states that between April 2010 and March 2020, the District achieved a total of 1,768 dwelling completions over this particular 10-year period – an average of just 177 dpa. Furthermore, the delivery of these 1,768 dwellings was not solely through urban
intensification, but also included allocations made through the Rochford Allocations Plan (2014). There is of course only a finite supply of previously developed land that is
suitable and viable for residential redevelopment, and it is considered that much of this has likely already been exhausted, particularly given the emphasis placed by national and local policy on utilising such sites.
3.9 In addition to Strategy Option 1 being unlikely to deliver anywhere near the number of new homes needed in the District, we would also question the appropriateness of such a strategy in any case. To make a meaningful contribution to housing needs over the
plan period, this strategy would likely require development at a significantly greater density than existing development in the District. Not only could this be harmful to the character of the District’s residential areas, but it may also result in loss of amenity for existing residents.
3.10 Furthermore, it is unclear if this approach would deliver the types of homes required where they are required in the District. Such a strategy is, for example, unlikely to deliver a high proportion of family homes.
3.11 For the above reasons, we do not consider that Strategy Option 1 is capable of resulting in a sound Local Plan and should be discounted.
Strategy Options 2, 3 and 4
3.12 Given Strategy Option 1’s inability to result in a sound Local Plan, this leaves Options 2, 3 and 4 as potential strategies.
3.13 Strategy Option 2 is to focus on urban extensions, with Option 2a entailing focussing such growth on the District’s main towns; and Option 2b dispersing to all settlements based on the settlement hierarchy.
3.14 Through Strategy Option 2 sustainable sites could be utilised at the edge of settlements, which should include Hockley, to deliver a range of housing developments, including the provision of much needed housing in the short term. This option provides flexibility to utilise smaller sites to deliver homes earlier alongside larger sites to meet the overall housing need.
3.15 We consider that Strategy Option 2b should include growth to Hockley, given that it is a top tier settlement in the adopted Development Plan’s settlement hierarchy.
3.16 In relation to Option 3, this suggests focussing growth on one of three locations (west of Rayleigh (3a); north of Southend (3b); and east of Rochford (3c)). We consider there is merit to strategic scale growth that can help deliver significant infrastructure improvements. However, this needs to be complemented by the delivery of a range of different sites (including those that can deliver in the short term and do not require
significant infrastructure improvements) and in a range of different locations that reflect the fact that the District comprises a number of distinct settlements with their own
identities and communities, all of which the Local Plan should seek to support.
3.17 The outcome of the Uttlesford Local Plan Examination provdes a warning regarding the dangers of over reliance on large strategic growth sites to meet housing needs. Recommending the submitted plan be withdrawn due to soundness issues, the Inspectors concluded:
“In order to arrive at a sound strategy, we consider that as a primary consideration, the Council would need to allocate more small and medium sized sites that could
deliver homes in the short to medium term and help to bolster the 5 year [housing land supply], until the Garden Communities begin to deliver housing. This would have
the benefit of providing flexibility and choice in the market and the earlier provision of more affordable housing”. (Paragraph 114 of Uttlesford Local Plan Examination
Inspectors’ letter of 10 January 2020)
3.18 This does not of course mean that the strategy cannot include strategic growth allocations, only that if it were to, they would need to be accompanied by a range of other small and medium sized sites.
3.19 Strategy Option 4 entails a mix of the other options, and rightly recognises that the alloction of strategic growth sites and the allocation of urban extensions are not mutually exclusive. We consider this option does have particular merit, and it is notable that it was scored positively by the Integrated Impact Assessment (IIA) in relation to its social, economic and environmental impacts. This option will still allow for current housing
needs to be addressed in the short term, as the Local Plan is required to; as well as enabling provision of strategic allocations if so wished. It will also allow for proportionate growth to be directed to the District’s various communities through settlement extensions, including Hockley – something which we consider is essential for the Local Plan to do if it is to deliver sustainable development.
Hockley
3.20 We consider that, in order for the Local Plan’s spatial strategy to promote sustainable development, to be justified, and to be capable of being found sound, it will be essential for it to direct a proportion of the District’s growth to Hockley.
3.21 Hockley / Hawkwell is identified as a Tier 1 settlement in the current Development Plan, i.e. one of the settlements considered most sustainable to accommodate greatest levels of growth.
3.22 Notwithstanding this, the District has experienced considerably less housing development since adoption of the Core Strategy than the other two Tier 1 settlements.
It is recognised that this is in part due to aspirations for the redevelopment of the town centre not being realised, as conditions have changed; and also partly due to constraints to the settlement’s growth as a result of Hockley Woods and the Upper Roach Valley Special Landscape Area to the south. Nevertheless, there are opportunities to deliver sustainable extensions to the existing settlement, particularly located away from the
more sensitive areas to the south.
3.23 Hockley is an established, vibrant community with a long history. It is important that planning helps support and enhance the vitality of the community, including by directing future growth to the settlement.
3.24 The RLPSO recognises that housing affordability and availability are key issues in Hockley. The Local Plan represents an opportunity to help address this issue, by
directing additional housing to this location. Conversely, failure to direct sufficient housing to Hockley is likely to result in housing becoming increasingly unaffordable for
local people. It is manifestly clear that if the Local Plan is to be a sound plan that meets development needs in a sustainable manner, then it cannot rely on RLPSO Option 1.
Alterations to the Green Belt boundary
3.25 It is evident that the District’s Green Belt boundaries will need to be amended in order to meet development needs and provide a sound plan for the future of the District.
3.26 The NPPF confirms (paragraph 140) that Local Plans are the appropriate vehicle through which to make alterations to the Green Belt boundary.
3.27 The NPPF (paragraph 140 again) also states that such alterations should only be made where exceptional circumstances are fully evidenced and justified.
3.28 Exceptional circumstances are not defined in national policy or guidance.
3.29 However, there is case law which provides a basis for the consideration of the issue. In particular, the judgment in Calverton Parish Council v Nottingham City Council & Ors [2015] EWHC 1078 (Admin) suggests (paragraph 51) that the following matters are relevant in the consideration of whether exceptional circumstances exist to justify alterations to the Green Belt:
 The scale of the objectively assessed need;
 Constraints on supply/availability of land with the potential to accommodate sustainable development;
 Difficulties in achieving sustainable development without impinging on the Green Belt;
 The nature and extent of the harm to the Green Belt; and  The extent to which impacts on the purposes of the Green Belt may be mitigated as far as practicable.
3.30 The District is subject to an acute local housing need. The existing Green Belt boundary
is drawn tightly around the District’s existing settlements, and opportunities to meet development needs are severely restricted without alterations to the Green Belt
boundary.
3.31 Given the scale of objectively assessed need faced by the District, and the lack of potential alternatives to releasing Green Belt in order to sustainably meet such needs, it is evident that there are exceptional circumstances that justify alteration to the Green
Belt through the Rochford Local Plan.
4.0 Response to Local Plan Spatial Options Question 29
Do you agree that the plan should designate and protect areas of land of locally important wildlife value as a local wildlife site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection?
4.1 We agree that the Local Plan should seek to protect areas of locally important wildlife. Furthermore, we consider it should seek to deliver ecological gains.
4.2 However, the designation of such sites must be justified by robust evidence.
4.3 The 2018 Local Wildlife Review suggested a new Local Wildlife Site (R41) which
incorporates some of what is currently Local Wildlife Site R24, along with additional land to the west of this, including part of the Land at Pulpits Farm (CFS263 (‘the Site’).
4.4 The evidence for designating such additional land as a Local Wildlife Site is unclear.
4.5 It is not clear from the 2018 Local Wildlife Site Review what particular characteristics of the land forming part of CFS263 proposed to be designated as a Local Wildlife Site justify this land’s designation as such.
4.6 There is no evidence that a detailed survey of the Site was undertaken as part of the 2018 Local Wildlife Site Review that could justify its inclusion within a Local Wildlife Site.
4.7 The Site has been subject to an ecological constraints and opportunities survey, undertaken in 2020 by qualified specialist ecological consultancy, Southern Ecological Solutions.
4.8 This survey identified that the Site comprises habitats of varying value to biodiversity, with the most suitable habitat at the Site’s boundaries in the form of hedgerows, mature trees, rough grassland margins and watercourses. However, there was nothing to suggest that the Site merits any form of designation for its ecological value.
4.9 A copy of this initial survey is provided as Appendix B to these representations.
4.10 It is not the case that evidence must be provided to set out why the Site should not form part of the Local Wildlife Site. On the contrary, if this land is to be designated as a Local Wildlife Site, it is incumbent upon the Council to provide robust evidence justifying this.
4.11 We do not consider the Site merits designation for its ecological value, and would object to any proposals to do so. However, we do recognise that parts of the Site are of
ecological value. As part of the development of the Site, existing ecological features would be retained and, where practicable, enhanced.
4.12 It is important to recognise that development of land often has the potential to engender ecological benefits, and that would be the case in the development of site CFS263.
5.0 Response to Local Plan Spatial Options Question 58
Q58a. Do you agree with our vision for Hockley and Hawkwell? Is there anything you feel is missing?
5.1 We agree with the vision for Hockley as proposed by the RLPSO.
5.2 In particular, we very much support the objective of improving housing affordability in order to ensure that local first-time buyers can afford to live locally.
5.3 If this vision is to be realised, it will be imperative to provide a sufficient number of new homes for Hockley, and of a variety of types and tenures, to meet all of the community’s needs.
Q58b. With reference to Figure 46 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 Hockley and Hawkwell?
i. Housing
5.4 Land at Pulpits Farm (CFS263, ‘the Site’) is suitable, available, and achievable for residential development as a sustainable extension to Hockley. The Vision Document
which accompanies this representation (Appendix A) sets out details regarding the Site’s ability to sustainably deliver a high-quality development.
5.5 The Site was considered through the Council’s Strategic Housing Land Availability Assessment (SHELAA) (2020). The SHELAA (2020) considered the Site’s suitability in relation to a multitude of constraints, including policy, environmental, ecological, heritage
and physical constraints. In respect of the Site and potential constraints, this assessment concluded:
“Green Belt site that is currently in mixed use with residential and ancillary outbuildings, with some vacant grassland. There is an existing access with no
fundamental constraints to redevelopment of the site” [Emphasis added].
5.6 In summary, the only constraint to the Site’s development identified was its location within the Green Belt in the current Development Plan – a policy constraint.
5.7 In addition, the SHELAA (2020) assessed the Site’s suitability in terms of its accessibility to local services.
5.8 In relation to accessibility alone, it stated:
“There are two bus stops within c 0.3km of the site, however these are served by only two bus routes (No7/18). A private road connects the site to Greensward Lane, a C road which traverses the centre of Hockley before connecting to the wider strategic road network”
5.9 In addition to the points made within the SHELAA (2020) we would add that the Site is c.12 minutes walking distance from Hockley railway station. When considering
accessibility of this Site, and its appropriateness for allocation, this is clearly a key consideration.
5.10 In particular, it is important to note that the NPPF instructs Local Planning Authorities to prioritise sites that have good access to public transport when considering release of Green Belt to meet development needs. At paragraph 142 of the NPPF it states:
“Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previouslydeveloped and/or is well-served by public transport”.
5.11 The Green Belt is drawn tightly around the existing extent of residential development in Hockley. As noted in our response to Question 6, Hockley is clearly a sustainable location to accommodate a proportion of the District’s housing needs, and furthermore it is important that the vitality of Hockley be supported through the direction of sustainable growth to the settlement. It will be necessary to direct some growth to Hockley in order to ensure a sound Local Plan that delivers sustainable development, and to deliver this it will be necessary to alter the existing Green Belt boundary. In making such a revision, sites such as CFS263 which have good access to public transport should be prioritised for residential allocation.
5.12 The SHELAA (2020) considered the Site’s proximity to local services and stated: “A primary school sits c 1km to the east of the site, with a secondary school c 0.6km
to the west. A garden centres [sic] sits within C 0.3km of the site with a small number of shops along Greensward Lane”.
5.13 We consider the above significantly understates the range of local services and facilities that are in proximity to the Site.
5.14 In particular, the SHELAA (2020) appears to have overlooked that the Site is adjacent to
a GP surgery.
5.15 The Site is also well located in relation to a range of other services, facilities, employment opportunities and centres. As set out in the Vision Document that accompanies this representation, the following can be reached without use of a car within the following
journey times:
Walking:
Bus stop 1 minute
Greensward Surgery 1 minute
Greensward Academy Secondary School 5 minutes
Hockley Railway Station 12 minutes
Plumberow Academy Primary School 15 minutes
Convenience retail (Co-Op, Spa Road) 15 minutes
Hockley Post Office 15 minutes
Eldon Way 15 minutes
Approximate centre of Hockley Town Centre 17 minutes
Bus:
Approximate centre of Hockley Town Centre 5 minutes
Rochford Town Centre 14 minutes
Rayleigh Town Centre 16 minutes
Train:
Southend Victoria 27 minutes
London Liverpool Street 60 minutes
5.16 In 2014, sustainable transport charity Sustrans estimated that school traffic contributed,
nationally, to 24% of all traffic at peak times. The accessibility of both primary and
secondary schools from the Site without reliance on a car, and the potential to avoid
additional traffic that might be otherwise generated, is considered to be a factor which
weighs significantly in favour of utilising this Site to help meet housing needs.
5.17 The principal constraint to the Site’s development is that it is currently within the Green Belt.
5.18 In terms of the Site’s contribution to the purposes of the Green Belt, it is relevant to note that is an edge-of-settlement Site, the character of which has been influenced by adjacent residential uses to the north, west and south. The Site is subject to a degree of containment provided by existing features, and its development would not give rise to unrestricted urban sprawl. On the contrary, it would allow for a new, robust Green Belt
boundary to be implemented.
5.19 The Council’s Rochford District and Southend-on-Sea Borough Joint Green Belt Study February 2020 (‘the Green Belt Study (2020)’ concluded that the western portion of the Site could be developed with only moderate harm to the Green Belt. This is before mitigation measures are factored in (which case law suggests must be considered in determining whether exceptional circumstances apply), and once potential measures are
accounted for (such as provision of landscape buffers) it is considered that the Site’s development would not undermine the strategic purposes of the Green Belt.
5.20 Use of the Site to provide market and affordable homes would result in a number of social, economic and environmental benefits, as set out within the Vision Document
(Appendix A). These include, in summary:
 Market and affordable homes to help meet acute local need;
 Highly accessible Site, with opportunities for future residents to access services and facilities without use of a car;
 Efficient use of land which lacks environmental constraints, reducing pressure to develop more sensitive sites to meet needs;
 Provision of variety of public open space across the Site, including informal open space, ponds, structural landscaping for wildlife;
Increased expenditure within the local area, supporting jobs and helping sustain local facilities and services;
 Creation of direct employment during construction, as well as indirect employment related to the supply chain;
 Landscape and ecological enhancements as part of development;
 Development within a location that will help sustain the vitality of Hockley Town Centre.
5.21 It is important that where Green Belt is released for housing, the Council can have confidence that such land will be delivered and contribute to meeting needs.
5.22 In addition to being suitable and sustainable, the Site is also available and achievable for residential development.
5.23 The Site is not subject to any legal or ownership constraints to development.
5.24 The Site is being actively promoted for development by an established housebuilder with a track record of delivery. The Council can be confident that the Site will be deliver, and through a high-quality development, if allocated through the Local Plan.
6.0 Comments on Integrated Impact Assessment
Assessment Framework
6.1 At Table 1.1 of the Integrated Impact Assessment (IIA), the assessment framework is set out. This explains that the objectives of the population and communities theme are
1) to cater for existing and future residents’ needs as well as the needs of different groups in the community; and 2) maintain and enhance community and settlement identity.
6.2 In respective of objective 1, Table 1.1 explains that assessment questions relate to the following:
 Meet the identified objectively assessed housing needs, including affordable, for the plan area?
 Ensure an appropriate mix of dwelling sizes, types and tenures to meet the needs of all sectors of the community?
 Improve cross-boundary links between communities?
 Provide housing in sustainable locations that allow easy access to a range of local services and facilities?
 Promote the development of a range of high quality, accessible community facilities, including specialist services for disabled and older people?
6.3 We support the above decision-aiding question, but suggest that, in addition to meeting the District’s housing needs (including affordable housing), the Local Plan should seek to improve the affordability of housing for local residents.
6.4 The median house price in the District is 11.57 times the median gross annual workplacebased earnings (‘the affordability ratio’). The affordability of housing has worsened significantly in recent years – and to a much greater extent than the national average. In 2000, the affordability ratio for the District was 5.08 – only slightly worse than the national average of 4.13. By 2020, the national affordability ratio had increased to 7.69 –
significantly below the District’s 11.57.

1.0 Introduction
1.1 These representations are submitted to the Rochford New Local Plan Spatial Options (RLPSO) on behalf of Countryside Properties and in respect of Land at Pulpits Farm, Hockley.
1.2 The Site has previously been submitted in response to the Council’s Call for Sites, and is reference CFS263 in the Council’s plan-making process (although also referred to as Site 272, in the Council’s Green Belt Study (2020))
1.3 This representation should be read alongside the Vision Document that has been prepared in respect of the development of the Site, and which accompanies the
representations as Appendix A.
2.0 Response to Local Plan Spatial Options Question 4
Q4. Do you agree with the strategic priorities and objectives we have identifies? Is there anything missing from the strategic priorities or objectives that you feel
needs to be included?
2.1 We suggest that improving the affordability of housing for local people in Rochford District should form an objective of the Local Plan.
2.2 As the RLPSO rightly recognises at page 12, housing affordability is a particularly issue within the District.
2.3 ONS data on the affordability of housing reports that in 2020 the median house price was 11.57 times the median gross annual workplace-based earnings. The affordability of housing has worsened significantly in recent years, and is substantially worse than the
national average.
2.4 Without an increase in housing supply, we consider there is a very real risk that it will only worsen.
2.5 Not only do current projections suggest increased housing need in the District, but the longer term impact of the Covid-19 pandemic may well place additional pressure on Rochford’s housing market and affordability of homes for local people.
2.6 Early indications are that there has already been an increased desire to move from more to less urban areas, due to a combination of a desire for homes with larger garden areas and home offices, better access to open space, and within less densely populated areas; and people considering it less critical to live very near their place of work, given the increase in home working within a number of employment sectors.
2.7 This is of particular relevance to Rochford District, given that London is accessible via railway services from parts of the District; and house prices are relatively affordable when compared to other areas in and around London.
3.0 Response to Local Plan Spatial Options Question 6
Which of the identified strategy options do you consider should be taken forward in the Plan?
3.1 We consider that a balanced approach that includes direction of a relatively significant proportion of the District’s housing needs to the higher tier settlements (including Hockley) would be the most appropriate strategy, for the reason set out below.
Strategy Option 1 – Urban Intensification
3.2 The RLPSO states that this option would entail making best possible use of our existing planned developments, previously developed land and other under-utilised land, such as vacant buildings and contaminated land; and notes that a strategy based on urban intensification could also include taking a more permissive approach to higher densities in suitable locations (such as town centres and near stations). It is suggested this would involve no loss of Green Belt land, would minimise loss of greenfield, and would deliver
4,200 homes over the next 10 years.
3.3 The RLPSO describes Strategy Option 1 as “the minimum expectation of national policy” and states it is “likely to be required within every strategy option”.
3.4 We agree that it would be consistent with national policy to seek to promote the redevelopment of appropriate previously developed land to help meet development needs. However, we consider that a strategy which were to rely purely on this to meet development needs would be ineffective, unsustainable, incapable of meeting development needs in full as required by national policy, and result in a Local Plan that would be inherently unsound.
3.5 The National Planning Policy Framework (NPPF) confirms (paragraph 35) that one of the requirements of a sound Local Plan is that it seeks to meet the area’s objectively assessed development needs in full. The NPPF also emphasises the Government’s objective to significantly boost housing land supply (paragraph 60).
3.6 However, the RLPSO acknowledges that Strategy Option 1 would fall significantly short of meeting local development needs in full. Not only would this render the plan unsound and contrary to the NPPF, but it would likely result in significant negative social and economic impacts locally.
3.7 In any case, we consider that a yield of 4,200 dwellings over 10 years through urban intensification to be unfeasibly optimistic.
3.8 To achieve this quantum, it would be necessary to sustain an average of 420 dwellings per annum (dpa) over a 10-year period. The Council’s Annual Monitoring Report 2019/20 states that between April 2010 and March 2020, the District achieved a total of 1,768 dwelling completions over this particular 10-year period – an average of just 177 dpa. Furthermore, the delivery of these 1,768 dwellings was not solely through urban
intensification, but also included allocations made through the Rochford Allocations Plan (2014). There is of course only a finite supply of previously developed land that is
suitable and viable for residential redevelopment, and it is considered that much of this has likely already been exhausted, particularly given the emphasis placed by national and local policy on utilising such sites.
3.9 In addition to Strategy Option 1 being unlikely to deliver anywhere near the number of new homes needed in the District, we would also question the appropriateness of such a strategy in any case. To make a meaningful contribution to housing needs over the
plan period, this strategy would likely require development at a significantly greater density than existing development in the District. Not only could this be harmful to the character of the District’s residential areas, but it may also result in loss of amenity for existing residents.
3.10 Furthermore, it is unclear if this approach would deliver the types of homes required where they are required in the District. Such a strategy is, for example, unlikely to deliver a high proportion of family homes.
3.11 For the above reasons, we do not consider that Strategy Option 1 is capable of resulting in a sound Local Plan and should be discounted.
Strategy Options 2, 3 and 4
3.12 Given Strategy Option 1’s inability to result in a sound Local Plan, this leaves Options 2, 3 and 4 as potential strategies.
3.13 Strategy Option 2 is to focus on urban extensions, with Option 2a entailing focussing such growth on the District’s main towns; and Option 2b dispersing to all settlements based on the settlement hierarchy.
3.14 Through Strategy Option 2 sustainable sites could be utilised at the edge of settlements, which should include Hockley, to deliver a range of housing developments, including the provision of much needed housing in the short term. This option provides flexibility to utilise smaller sites to deliver homes earlier alongside larger sites to meet the overall housing need.
3.15 We consider that Strategy Option 2b should include growth to Hockley, given that it is a top tier settlement in the adopted Development Plan’s settlement hierarchy.
3.16 In relation to Option 3, this suggests focussing growth on one of three locations (west of Rayleigh (3a); north of Southend (3b); and east of Rochford (3c)). We consider there is merit to strategic scale growth that can help deliver significant infrastructure improvements. However, this needs to be complemented by the delivery of a range of different sites (including those that can deliver in the short term and do not require
significant infrastructure improvements) and in a range of different locations that reflect the fact that the District comprises a number of distinct settlements with their own
identities and communities, all of which the Local Plan should seek to support.
3.17 The outcome of the Uttlesford Local Plan Examination provdes a warning regarding the dangers of over reliance on large strategic growth sites to meet housing needs. Recommending the submitted plan be withdrawn due to soundness issues, the Inspectors concluded:
“In order to arrive at a sound strategy, we consider that as a primary consideration, the Council would need to allocate more small and medium sized sites that could
deliver homes in the short to medium term and help to bolster the 5 year [housing land supply], until the Garden Communities begin to deliver housing. This would have
the benefit of providing flexibility and choice in the market and the earlier provision of more affordable housing”. (Paragraph 114 of Uttlesford Local Plan Examination
Inspectors’ letter of 10 January 2020)
3.18 This does not of course mean that the strategy cannot include strategic growth allocations, only that if it were to, they would need to be accompanied by a range of other small and medium sized sites.
3.19 Strategy Option 4 entails a mix of the other options, and rightly recognises that the alloction of strategic growth sites and the allocation of urban extensions are not mutually exclusive. We consider this option does have particular merit, and it is notable that it was scored positively by the Integrated Impact Assessment (IIA) in relation to its social, economic and environmental impacts. This option will still allow for current housing
needs to be addressed in the short term, as the Local Plan is required to; as well as enabling provision of strategic allocations if so wished. It will also allow for proportionate growth to be directed to the District’s various communities through settlement extensions, including Hockley – something which we consider is essential for the Local Plan to do if it is to deliver sustainable development.
Hockley
3.20 We consider that, in order for the Local Plan’s spatial strategy to promote sustainable development, to be justified, and to be capable of being found sound, it will be essential for it to direct a proportion of the District’s growth to Hockley.
3.21 Hockley / Hawkwell is identified as a Tier 1 settlement in the current Development Plan, i.e. one of the settlements considered most sustainable to accommodate greatest levels of growth.
3.22 Notwithstanding this, the District has experienced considerably less housing development since adoption of the Core Strategy than the other two Tier 1 settlements.
It is recognised that this is in part due to aspirations for the redevelopment of the town centre not being realised, as conditions have changed; and also partly due to constraints to the settlement’s growth as a result of Hockley Woods and the Upper Roach Valley Special Landscape Area to the south. Nevertheless, there are opportunities to deliver sustainable extensions to the existing settlement, particularly located away from the
more sensitive areas to the south.
3.23 Hockley is an established, vibrant community with a long history. It is important that planning helps support and enhance the vitality of the community, including by directing future growth to the settlement.
3.24 The RLPSO recognises that housing affordability and availability are key issues in Hockley. The Local Plan represents an opportunity to help address this issue, by
directing additional housing to this location. Conversely, failure to direct sufficient housing to Hockley is likely to result in housing becoming increasingly unaffordable for
local people. It is manifestly clear that if the Local Plan is to be a sound plan that meets development needs in a sustainable manner, then it cannot rely on RLPSO Option 1.
Alterations to the Green Belt boundary
3.25 It is evident that the District’s Green Belt boundaries will need to be amended in order to meet development needs and provide a sound plan for the future of the District.
3.26 The NPPF confirms (paragraph 140) that Local Plans are the appropriate vehicle through which to make alterations to the Green Belt boundary.
3.27 The NPPF (paragraph 140 again) also states that such alterations should only be made where exceptional circumstances are fully evidenced and justified.
3.28 Exceptional circumstances are not defined in national policy or guidance.
3.29 However, there is case law which provides a basis for the consideration of the issue. In particular, the judgment in Calverton Parish Council v Nottingham City Council & Ors [2015] EWHC 1078 (Admin) suggests (paragraph 51) that the following matters are relevant in the consideration of whether exceptional circumstances exist to justify alterations to the Green Belt:
 The scale of the objectively assessed need;
 Constraints on supply/availability of land with the potential to accommodate sustainable development;
 Difficulties in achieving sustainable development without impinging on the Green Belt;
 The nature and extent of the harm to the Green Belt; and  The extent to which impacts on the purposes of the Green Belt may be mitigated as far as practicable.
3.30 The District is subject to an acute local housing need. The existing Green Belt boundary
is drawn tightly around the District’s existing settlements, and opportunities to meet development needs are severely restricted without alterations to the Green Belt
boundary.
3.31 Given the scale of objectively assessed need faced by the District, and the lack of potential alternatives to releasing Green Belt in order to sustainably meet such needs, it is evident that there are exceptional circumstances that justify alteration to the Green
Belt through the Rochford Local Plan.
4.0 Response to Local Plan Spatial Options Question 29
Do you agree that the plan should designate and protect areas of land of locally important wildlife value as a local wildlife site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection?
4.1 We agree that the Local Plan should seek to protect areas of locally important wildlife. Furthermore, we consider it should seek to deliver ecological gains.
4.2 However, the designation of such sites must be justified by robust evidence.
4.3 The 2018 Local Wildlife Review suggested a new Local Wildlife Site (R41) which
incorporates some of what is currently Local Wildlife Site R24, along with additional land to the west of this, including part of the Land at Pulpits Farm (CFS263 (‘the Site’).
4.4 The evidence for designating such additional land as a Local Wildlife Site is unclear.
4.5 It is not clear from the 2018 Local Wildlife Site Review what particular characteristics of the land forming part of CFS263 proposed to be designated as a Local Wildlife Site justify this land’s designation as such.
4.6 There is no evidence that a detailed survey of the Site was undertaken as part of the 2018 Local Wildlife Site Review that could justify its inclusion within a Local Wildlife Site.
4.7 The Site has been subject to an ecological constraints and opportunities survey, undertaken in 2020 by qualified specialist ecological consultancy, Southern Ecological Solutions.
4.8 This survey identified that the Site comprises habitats of varying value to biodiversity, with the most suitable habitat at the Site’s boundaries in the form of hedgerows, mature trees, rough grassland margins and watercourses. However, there was nothing to suggest that the Site merits any form of designation for its ecological value.
4.9 A copy of this initial survey is provided as Appendix B to these representations.
4.10 It is not the case that evidence must be provided to set out why the Site should not form part of the Local Wildlife Site. On the contrary, if this land is to be designated as a Local Wildlife Site, it is incumbent upon the Council to provide robust evidence justifying this.
4.11 We do not consider the Site merits designation for its ecological value, and would object to any proposals to do so. However, we do recognise that parts of the Site are of
ecological value. As part of the development of the Site, existing ecological features would be retained and, where practicable, enhanced.
4.12 It is important to recognise that development of land often has the potential to engender ecological benefits, and that would be the case in the development of site CFS263.
5.0 Response to Local Plan Spatial Options Question 58
Q58a. Do you agree with our vision for Hockley and Hawkwell? Is there anything you feel is missing?
5.1 We agree with the vision for Hockley as proposed by the RLPSO.
5.2 In particular, we very much support the objective of improving housing affordability in order to ensure that local first-time buyers can afford to live locally.
5.3 If this vision is to be realised, it will be imperative to provide a sufficient number of new homes for Hockley, and of a variety of types and tenures, to meet all of the community’s needs.
Q58b. With reference to Figure 46 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 Hockley and Hawkwell?
i. Housing
5.4 Land at Pulpits Farm (CFS263, ‘the Site’) is suitable, available, and achievable for residential development as a sustainable extension to Hockley. The Vision Document
which accompanies this representation (Appendix A) sets out details regarding the Site’s ability to sustainably deliver a high-quality development.
5.5 The Site was considered through the Council’s Strategic Housing Land Availability Assessment (SHELAA) (2020). The SHELAA (2020) considered the Site’s suitability in relation to a multitude of constraints, including policy, environmental, ecological, heritage
and physical constraints. In respect of the Site and potential constraints, this assessment concluded:
“Green Belt site that is currently in mixed use with residential and ancillary outbuildings, with some vacant grassland. There is an existing access with no
fundamental constraints to redevelopment of the site” [Emphasis added].
5.6 In summary, the only constraint to the Site’s development identified was its location within the Green Belt in the current Development Plan – a policy constraint.
5.7 In addition, the SHELAA (2020) assessed the Site’s suitability in terms of its accessibility to local services.
5.8 In relation to accessibility alone, it stated:
“There are two bus stops within c 0.3km of the site, however these are served by only two bus routes (No7/18). A private road connects the site to Greensward Lane, a C road which traverses the centre of Hockley before connecting to the wider strategic road network”
5.9 In addition to the points made within the SHELAA (2020) we would add that the Site is c.12 minutes walking distance from Hockley railway station. When considering
accessibility of this Site, and its appropriateness for allocation, this is clearly a key consideration.
5.10 In particular, it is important to note that the NPPF instructs Local Planning Authorities to prioritise sites that have good access to public transport when considering release of Green Belt to meet development needs. At paragraph 142 of the NPPF it states:
“Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previouslydeveloped and/or is well-served by public transport”.
5.11 The Green Belt is drawn tightly around the existing extent of residential development in Hockley. As noted in our response to Question 6, Hockley is clearly a sustainable location to accommodate a proportion of the District’s housing needs, and furthermore it is important that the vitality of Hockley be supported through the direction of sustainable growth to the settlement. It will be necessary to direct some growth to Hockley in order to ensure a sound Local Plan that delivers sustainable development, and to deliver this it will be necessary to alter the existing Green Belt boundary. In making such a revision, sites such as CFS263 which have good access to public transport should be prioritised for residential allocation.
5.12 The SHELAA (2020) considered the Site’s proximity to local services and stated: “A primary school sits c 1km to the east of the site, with a secondary school c 0.6km
to the west. A garden centres [sic] sits within C 0.3km of the site with a small number of shops along Greensward Lane”.
5.13 We consider the above significantly understates the range of local services and facilities that are in proximity to the Site.
5.14 In particular, the SHELAA (2020) appears to have overlooked that the Site is adjacent to
a GP surgery.
5.15 The Site is also well located in relation to a range of other services, facilities, employment opportunities and centres. As set out in the Vision Document that accompanies this representation, the following can be reached without use of a car within the following
journey times:
Walking:
Bus stop 1 minute
Greensward Surgery 1 minute
Greensward Academy Secondary School 5 minutes
Hockley Railway Station 12 minutes
Plumberow Academy Primary School 15 minutes
Convenience retail (Co-Op, Spa Road) 15 minutes
Hockley Post Office 15 minutes
Eldon Way 15 minutes
Approximate centre of Hockley Town Centre 17 minutes
Bus:
Approximate centre of Hockley Town Centre 5 minutes
Rochford Town Centre 14 minutes
Rayleigh Town Centre 16 minutes
Train:
Southend Victoria 27 minutes
London Liverpool Street 60 minutes
5.16 In 2014, sustainable transport charity Sustrans estimated that school traffic contributed,
nationally, to 24% of all traffic at peak times. The accessibility of both primary and
secondary schools from the Site without reliance on a car, and the potential to avoid
additional traffic that might be otherwise generated, is considered to be a factor which
weighs significantly in favour of utilising this Site to help meet housing needs.
5.17 The principal constraint to the Site’s development is that it is currently within the Green Belt.
5.18 In terms of the Site’s contribution to the purposes of the Green Belt, it is relevant to note that is an edge-of-settlement Site, the character of which has been influenced by adjacent residential uses to the north, west and south. The Site is subject to a degree of containment provided by existing features, and its development would not give rise to unrestricted urban sprawl. On the contrary, it would allow for a new, robust Green Belt
boundary to be implemented.
5.19 The Council’s Rochford District and Southend-on-Sea Borough Joint Green Belt Study February 2020 (‘the Green Belt Study (2020)’ concluded that the western portion of the Site could be developed with only moderate harm to the Green Belt. This is before mitigation measures are factored in (which case law suggests must be considered in determining whether exceptional circumstances apply), and once potential measures are
accounted for (such as provision of landscape buffers) it is considered that the Site’s development would not undermine the strategic purposes of the Green Belt.
5.20 Use of the Site to provide market and affordable homes would result in a number of social, economic and environmental benefits, as set out within the Vision Document
(Appendix A). These include, in summary:
 Market and affordable homes to help meet acute local need;
 Highly accessible Site, with opportunities for future residents to access services and facilities without use of a car;
 Efficient use of land which lacks environmental constraints, reducing pressure to develop more sensitive sites to meet needs;
 Provision of variety of public open space across the Site, including informal open space, ponds, structural landscaping for wildlife;
Increased expenditure within the local area, supporting jobs and helping sustain local facilities and services;
 Creation of direct employment during construction, as well as indirect employment related to the supply chain;
 Landscape and ecological enhancements as part of development;
 Development within a location that will help sustain the vitality of Hockley Town Centre.
5.21 It is important that where Green Belt is released for housing, the Council can have confidence that such land will be delivered and contribute to meeting needs.
5.22 In addition to being suitable and sustainable, the Site is also available and achievable for residential development.
5.23 The Site is not subject to any legal or ownership constraints to development.
5.24 The Site is being actively promoted for development by an established housebuilder with a track record of delivery. The Council can be confident that the Site will be deliver, and through a high-quality development, if allocated through the Local Plan.
6.0 Comments on Integrated Impact Assessment
Assessment Framework
6.1 At Table 1.1 of the Integrated Impact Assessment (IIA), the assessment framework is set out. This explains that the objectives of the population and communities theme are
1) to cater for existing and future residents’ needs as well as the needs of different groups in the community; and 2) maintain and enhance community and settlement identity.
6.2 In respective of objective 1, Table 1.1 explains that assessment questions relate to the following:
 Meet the identified objectively assessed housing needs, including affordable, for the plan area?
 Ensure an appropriate mix of dwelling sizes, types and tenures to meet the needs of all sectors of the community?
 Improve cross-boundary links between communities?
 Provide housing in sustainable locations that allow easy access to a range of local services and facilities?
 Promote the development of a range of high quality, accessible community facilities, including specialist services for disabled and older people?
6.3 We support the above decision-aiding question, but suggest that, in addition to meeting the District’s housing needs (including affordable housing), the Local Plan should seek to improve the affordability of housing for local residents.
6.4 The median house price in the District is 11.57 times the median gross annual workplacebased earnings (‘the affordability ratio’). The affordability of housing has worsened significantly in recent years – and to a much greater extent than the national average. In 2000, the affordability ratio for the District was 5.08 – only slightly worse than the national average of 4.13. By 2020, the national affordability ratio had increased to 7.69 –
significantly below the District’s 11.57.

1.0 Introduction
1.1 These representations are submitted to the Rochford New Local Plan Spatial Options (RLPSO) on behalf of Countryside Properties and in respect of Land at Pulpits Farm, Hockley.
1.2 The Site has previously been submitted in response to the Council’s Call for Sites, and is reference CFS263 in the Council’s plan-making process (although also referred to as Site 272, in the Council’s Green Belt Study (2020))
1.3 This representation should be read alongside the Vision Document that has been prepared in respect of the development of the Site, and which accompanies the
representations as Appendix A.
2.0 Response to Local Plan Spatial Options Question 4
Q4. Do you agree with the strategic priorities and objectives we have identifies? Is there anything missing from the strategic priorities or objectives that you feel
needs to be included?
2.1 We suggest that improving the affordability of housing for local people in Rochford District should form an objective of the Local Plan.
2.2 As the RLPSO rightly recognises at page 12, housing affordability is a particularly issue within the District.
2.3 ONS data on the affordability of housing reports that in 2020 the median house price was 11.57 times the median gross annual workplace-based earnings. The affordability of housing has worsened significantly in recent years, and is substantially worse than the
national average.
2.4 Without an increase in housing supply, we consider there is a very real risk that it will only worsen.
2.5 Not only do current projections suggest increased housing need in the District, but the longer term impact of the Covid-19 pandemic may well place additional pressure on Rochford’s housing market and affordability of homes for local people.
2.6 Early indications are that there has already been an increased desire to move from more to less urban areas, due to a combination of a desire for homes with larger garden areas and home offices, better access to open space, and within less densely populated areas; and people considering it less critical to live very near their place of work, given the increase in home working within a number of employment sectors.
2.7 This is of particular relevance to Rochford District, given that London is accessible via railway services from parts of the District; and house prices are relatively affordable when compared to other areas in and around London.
3.0 Response to Local Plan Spatial Options Question 6
Which of the identified strategy options do you consider should be taken forward in the Plan?
3.1 We consider that a balanced approach that includes direction of a relatively significant proportion of the District’s housing needs to the higher tier settlements (including Hockley) would be the most appropriate strategy, for the reason set out below.
Strategy Option 1 – Urban Intensification
3.2 The RLPSO states that this option would entail making best possible use of our existing planned developments, previously developed land and other under-utilised land, such as vacant buildings and contaminated land; and notes that a strategy based on urban intensification could also include taking a more permissive approach to higher densities in suitable locations (such as town centres and near stations). It is suggested this would involve no loss of Green Belt land, would minimise loss of greenfield, and would deliver
4,200 homes over the next 10 years.
3.3 The RLPSO describes Strategy Option 1 as “the minimum expectation of national policy” and states it is “likely to be required within every strategy option”.
3.4 We agree that it would be consistent with national policy to seek to promote the redevelopment of appropriate previously developed land to help meet development needs. However, we consider that a strategy which were to rely purely on this to meet development needs would be ineffective, unsustainable, incapable of meeting development needs in full as required by national policy, and result in a Local Plan that would be inherently unsound.
3.5 The National Planning Policy Framework (NPPF) confirms (paragraph 35) that one of the requirements of a sound Local Plan is that it seeks to meet the area’s objectively assessed development needs in full. The NPPF also emphasises the Government’s objective to significantly boost housing land supply (paragraph 60).
3.6 However, the RLPSO acknowledges that Strategy Option 1 would fall significantly short of meeting local development needs in full. Not only would this render the plan unsound and contrary to the NPPF, but it would likely result in significant negative social and economic impacts locally.
3.7 In any case, we consider that a yield of 4,200 dwellings over 10 years through urban intensification to be unfeasibly optimistic.
3.8 To achieve this quantum, it would be necessary to sustain an average of 420 dwellings per annum (dpa) over a 10-year period. The Council’s Annual Monitoring Report 2019/20 states that between April 2010 and March 2020, the District achieved a total of 1,768 dwelling completions over this particular 10-year period – an average of just 177 dpa. Furthermore, the delivery of these 1,768 dwellings was not solely through urban
intensification, but also included allocations made through the Rochford Allocations Plan (2014). There is of course only a finite supply of previously developed land that is
suitable and viable for residential redevelopment, and it is considered that much of this has likely already been exhausted, particularly given the emphasis placed by national and local policy on utilising such sites.
3.9 In addition to Strategy Option 1 being unlikely to deliver anywhere near the number of new homes needed in the District, we would also question the appropriateness of such a strategy in any case. To make a meaningful contribution to housing needs over the
plan period, this strategy would likely require development at a significantly greater density than existing development in the District. Not only could this be harmful to the character of the District’s residential areas, but it may also result in loss of amenity for existing residents.
3.10 Furthermore, it is unclear if this approach would deliver the types of homes required where they are required in the District. Such a strategy is, for example, unlikely to deliver a high proportion of family homes.
3.11 For the above reasons, we do not consider that Strategy Option 1 is capable of resulting in a sound Local Plan and should be discounted.
Strategy Options 2, 3 and 4
3.12 Given Strategy Option 1’s inability to result in a sound Local Plan, this leaves Options 2, 3 and 4 as potential strategies.
3.13 Strategy Option 2 is to focus on urban extensions, with Option 2a entailing focussing such growth on the District’s main towns; and Option 2b dispersing to all settlements based on the settlement hierarchy.
3.14 Through Strategy Option 2 sustainable sites could be utilised at the edge of settlements, which should include Hockley, to deliver a range of housing developments, including the provision of much needed housing in the short term. This option provides flexibility to utilise smaller sites to deliver homes earlier alongside larger sites to meet the overall housing need.
3.15 We consider that Strategy Option 2b should include growth to Hockley, given that it is a top tier settlement in the adopted Development Plan’s settlement hierarchy.
3.16 In relation to Option 3, this suggests focussing growth on one of three locations (west of Rayleigh (3a); north of Southend (3b); and east of Rochford (3c)). We consider there is merit to strategic scale growth that can help deliver significant infrastructure improvements. However, this needs to be complemented by the delivery of a range of different sites (including those that can deliver in the short term and do not require
significant infrastructure improvements) and in a range of different locations that reflect the fact that the District comprises a number of distinct settlements with their own
identities and communities, all of which the Local Plan should seek to support.
3.17 The outcome of the Uttlesford Local Plan Examination provdes a warning regarding the dangers of over reliance on large strategic growth sites to meet housing needs. Recommending the submitted plan be withdrawn due to soundness issues, the Inspectors concluded:
“In order to arrive at a sound strategy, we consider that as a primary consideration, the Council would need to allocate more small and medium sized sites that could
deliver homes in the short to medium term and help to bolster the 5 year [housing land supply], until the Garden Communities begin to deliver housing. This would have
the benefit of providing flexibility and choice in the market and the earlier provision of more affordable housing”. (Paragraph 114 of Uttlesford Local Plan Examination
Inspectors’ letter of 10 January 2020)
3.18 This does not of course mean that the strategy cannot include strategic growth allocations, only that if it were to, they would need to be accompanied by a range of other small and medium sized sites.
3.19 Strategy Option 4 entails a mix of the other options, and rightly recognises that the alloction of strategic growth sites and the allocation of urban extensions are not mutually exclusive. We consider this option does have particular merit, and it is notable that it was scored positively by the Integrated Impact Assessment (IIA) in relation to its social, economic and environmental impacts. This option will still allow for current housing
needs to be addressed in the short term, as the Local Plan is required to; as well as enabling provision of strategic allocations if so wished. It will also allow for proportionate growth to be directed to the District’s various communities through settlement extensions, including Hockley – something which we consider is essential for the Local Plan to do if it is to deliver sustainable development.
Hockley
3.20 We consider that, in order for the Local Plan’s spatial strategy to promote sustainable development, to be justified, and to be capable of being found sound, it will be essential for it to direct a proportion of the District’s growth to Hockley.
3.21 Hockley / Hawkwell is identified as a Tier 1 settlement in the current Development Plan, i.e. one of the settlements considered most sustainable to accommodate greatest levels of growth.
3.22 Notwithstanding this, the District has experienced considerably less housing development since adoption of the Core Strategy than the other two Tier 1 settlements.
It is recognised that this is in part due to aspirations for the redevelopment of the town centre not being realised, as conditions have changed; and also partly due to constraints to the settlement’s growth as a result of Hockley Woods and the Upper Roach Valley Special Landscape Area to the south. Nevertheless, there are opportunities to deliver sustainable extensions to the existing settlement, particularly located away from the
more sensitive areas to the south.
3.23 Hockley is an established, vibrant community with a long history. It is important that planning helps support and enhance the vitality of the community, including by directing future growth to the settlement.
3.24 The RLPSO recognises that housing affordability and availability are key issues in Hockley. The Local Plan represents an opportunity to help address this issue, by
directing additional housing to this location. Conversely, failure to direct sufficient housing to Hockley is likely to result in housing becoming increasingly unaffordable for
local people. It is manifestly clear that if the Local Plan is to be a sound plan that meets development needs in a sustainable manner, then it cannot rely on RLPSO Option 1.
Alterations to the Green Belt boundary
3.25 It is evident that the District’s Green Belt boundaries will need to be amended in order to meet development needs and provide a sound plan for the future of the District.
3.26 The NPPF confirms (paragraph 140) that Local Plans are the appropriate vehicle through which to make alterations to the Green Belt boundary.
3.27 The NPPF (paragraph 140 again) also states that such alterations should only be made where exceptional circumstances are fully evidenced and justified.
3.28 Exceptional circumstances are not defined in national policy or guidance.
3.29 However, there is case law which provides a basis for the consideration of the issue. In particular, the judgment in Calverton Parish Council v Nottingham City Council & Ors [2015] EWHC 1078 (Admin) suggests (paragraph 51) that the following matters are relevant in the consideration of whether exceptional circumstances exist to justify alterations to the Green Belt:
 The scale of the objectively assessed need;
 Constraints on supply/availability of land with the potential to accommodate sustainable development;
 Difficulties in achieving sustainable development without impinging on the Green Belt;
 The nature and extent of the harm to the Green Belt; and  The extent to which impacts on the purposes of the Green Belt may be mitigated as far as practicable.
3.30 The District is subject to an acute local housing need. The existing Green Belt boundary
is drawn tightly around the District’s existing settlements, and opportunities to meet development needs are severely restricted without alterations to the Green Belt
boundary.
3.31 Given the scale of objectively assessed need faced by the District, and the lack of potential alternatives to releasing Green Belt in order to sustainably meet such needs, it is evident that there are exceptional circumstances that justify alteration to the Green
Belt through the Rochford Local Plan.
4.0 Response to Local Plan Spatial Options Question 29
Do you agree that the plan should designate and protect areas of land of locally important wildlife value as a local wildlife site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection?
4.1 We agree that the Local Plan should seek to protect areas of locally important wildlife. Furthermore, we consider it should seek to deliver ecological gains.
4.2 However, the designation of such sites must be justified by robust evidence.
4.3 The 2018 Local Wildlife Review suggested a new Local Wildlife Site (R41) which
incorporates some of what is currently Local Wildlife Site R24, along with additional land to the west of this, including part of the Land at Pulpits Farm (CFS263 (‘the Site’).
4.4 The evidence for designating such additional land as a Local Wildlife Site is unclear.
4.5 It is not clear from the 2018 Local Wildlife Site Review what particular characteristics of the land forming part of CFS263 proposed to be designated as a Local Wildlife Site justify this land’s designation as such.
4.6 There is no evidence that a detailed survey of the Site was undertaken as part of the 2018 Local Wildlife Site Review that could justify its inclusion within a Local Wildlife Site.
4.7 The Site has been subject to an ecological constraints and opportunities survey, undertaken in 2020 by qualified specialist ecological consultancy, Southern Ecological Solutions.
4.8 This survey identified that the Site comprises habitats of varying value to biodiversity, with the most suitable habitat at the Site’s boundaries in the form of hedgerows, mature trees, rough grassland margins and watercourses. However, there was nothing to suggest that the Site merits any form of designation for its ecological value.
4.9 A copy of this initial survey is provided as Appendix B to these representations.
4.10 It is not the case that evidence must be provided to set out why the Site should not form part of the Local Wildlife Site. On the contrary, if this land is to be designated as a Local Wildlife Site, it is incumbent upon the Council to provide robust evidence justifying this.
4.11 We do not consider the Site merits designation for its ecological value, and would object to any proposals to do so. However, we do recognise that parts of the Site are of
ecological value. As part of the development of the Site, existing ecological features would be retained and, where practicable, enhanced.
4.12 It is important to recognise that development of land often has the potential to engender ecological benefits, and that would be the case in the development of site CFS263.
5.0 Response to Local Plan Spatial Options Question 58
Q58a. Do you agree with our vision for Hockley and Hawkwell? Is there anything you feel is missing?
5.1 We agree with the vision for Hockley as proposed by the RLPSO.
5.2 In particular, we very much support the objective of improving housing affordability in order to ensure that local first-time buyers can afford to live locally.
5.3 If this vision is to be realised, it will be imperative to provide a sufficient number of new homes for Hockley, and of a variety of types and tenures, to meet all of the community’s needs.
Q58b. With reference to Figure 46 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 Hockley and Hawkwell?
i. Housing
5.4 Land at Pulpits Farm (CFS263, ‘the Site’) is suitable, available, and achievable for residential development as a sustainable extension to Hockley. The Vision Document
which accompanies this representation (Appendix A) sets out details regarding the Site’s ability to sustainably deliver a high-quality development.
5.5 The Site was considered through the Council’s Strategic Housing Land Availability Assessment (SHELAA) (2020). The SHELAA (2020) considered the Site’s suitability in relation to a multitude of constraints, including policy, environmental, ecological, heritage
and physical constraints. In respect of the Site and potential constraints, this assessment concluded:
“Green Belt site that is currently in mixed use with residential and ancillary outbuildings, with some vacant grassland. There is an existing access with no
fundamental constraints to redevelopment of the site” [Emphasis added].
5.6 In summary, the only constraint to the Site’s development identified was its location within the Green Belt in the current Development Plan – a policy constraint.
5.7 In addition, the SHELAA (2020) assessed the Site’s suitability in terms of its accessibility to local services.
5.8 In relation to accessibility alone, it stated:
“There are two bus stops within c 0.3km of the site, however these are served by only two bus routes (No7/18). A private road connects the site to Greensward Lane, a C road which traverses the centre of Hockley before connecting to the wider strategic road network”
5.9 In addition to the points made within the SHELAA (2020) we would add that the Site is c.12 minutes walking distance from Hockley railway station. When considering
accessibility of this Site, and its appropriateness for allocation, this is clearly a key consideration.
5.10 In particular, it is important to note that the NPPF instructs Local Planning Authorities to prioritise sites that have good access to public transport when considering release of Green Belt to meet development needs. At paragraph 142 of the NPPF it states:
“Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previouslydeveloped and/or is well-served by public transport”.
5.11 The Green Belt is drawn tightly around the existing extent of residential development in Hockley. As noted in our response to Question 6, Hockley is clearly a sustainable location to accommodate a proportion of the District’s housing needs, and furthermore it is important that the vitality of Hockley be supported through the direction of sustainable growth to the settlement. It will be necessary to direct some growth to Hockley in order to ensure a sound Local Plan that delivers sustainable development, and to deliver this it will be necessary to alter the existing Green Belt boundary. In making such a revision, sites such as CFS263 which have good access to public transport should be prioritised for residential allocation.
5.12 The SHELAA (2020) considered the Site’s proximity to local services and stated: “A primary school sits c 1km to the east of the site, with a secondary school c 0.6km
to the west. A garden centres [sic] sits within C 0.3km of the site with a small number of shops along Greensward Lane”.
5.13 We consider the above significantly understates the range of local services and facilities that are in proximity to the Site.
5.14 In particular, the SHELAA (2020) appears to have overlooked that the Site is adjacent to
a GP surgery.
5.15 The Site is also well located in relation to a range of other services, facilities, employment opportunities and centres. As set out in the Vision Document that accompanies this representation, the following can be reached without use of a car within the following
journey times:
Walking:
Bus stop 1 minute
Greensward Surgery 1 minute
Greensward Academy Secondary School 5 minutes
Hockley Railway Station 12 minutes
Plumberow Academy Primary School 15 minutes
Convenience retail (Co-Op, Spa Road) 15 minutes
Hockley Post Office 15 minutes
Eldon Way 15 minutes
Approximate centre of Hockley Town Centre 17 minutes
Bus:
Approximate centre of Hockley Town Centre 5 minutes
Rochford Town Centre 14 minutes
Rayleigh Town Centre 16 minutes
Train:
Southend Victoria 27 minutes
London Liverpool Street 60 minutes
5.16 In 2014, sustainable transport charity Sustrans estimated that school traffic contributed,
nationally, to 24% of all traffic at peak times. The accessibility of both primary and
secondary schools from the Site without reliance on a car, and the potential to avoid
additional traffic that might be otherwise generated, is considered to be a factor which
weighs significantly in favour of utilising this Site to help meet housing needs.
5.17 The principal constraint to the Site’s development is that it is currently within the Green Belt.
5.18 In terms of the Site’s contribution to the purposes of the Green Belt, it is relevant to note that is an edge-of-settlement Site, the character of which has been influenced by adjacent residential uses to the north, west and south. The Site is subject to a degree of containment provided by existing features, and its development would not give rise to unrestricted urban sprawl. On the contrary, it would allow for a new, robust Green Belt
boundary to be implemented.
5.19 The Council’s Rochford District and Southend-on-Sea Borough Joint Green Belt Study February 2020 (‘the Green Belt Study (2020)’ concluded that the western portion of the Site could be developed with only moderate harm to the Green Belt. This is before mitigation measures are factored in (which case law suggests must be considered in determining whether exceptional circumstances apply), and once potential measures are
accounted for (such as provision of landscape buffers) it is considered that the Site’s development would not undermine the strategic purposes of the Green Belt.
5.20 Use of the Site to provide market and affordable homes would result in a number of social, economic and environmental benefits, as set out within the Vision Document
(Appendix A). These include, in summary:
 Market and affordable homes to help meet acute local need;
 Highly accessible Site, with opportunities for future residents to access services and facilities without use of a car;
 Efficient use of land which lacks environmental constraints, reducing pressure to develop more sensitive sites to meet needs;
 Provision of variety of public open space across the Site, including informal open space, ponds, structural landscaping for wildlife;
Increased expenditure within the local area, supporting jobs and helping sustain local facilities and services;
 Creation of direct employment during construction, as well as indirect employment related to the supply chain;
 Landscape and ecological enhancements as part of development;
 Development within a location that will help sustain the vitality of Hockley Town Centre.
5.21 It is important that where Green Belt is released for housing, the Council can have confidence that such land will be delivered and contribute to meeting needs.
5.22 In addition to being suitable and sustainable, the Site is also available and achievable for residential development.
5.23 The Site is not subject to any legal or ownership constraints to development.
5.24 The Site is being actively promoted for development by an established housebuilder with a track record of delivery. The Council can be confident that the Site will be deliver, and through a high-quality development, if allocated through the Local Plan.
6.0 Comments on Integrated Impact Assessment
Assessment Framework
6.1 At Table 1.1 of the Integrated Impact Assessment (IIA), the assessment framework is set out. This explains that the objectives of the population and communities theme are
1) to cater for existing and future residents’ needs as well as the needs of different groups in the community; and 2) maintain and enhance community and settlement identity.
6.2 In respective of objective 1, Table 1.1 explains that assessment questions relate to the following:
 Meet the identified objectively assessed housing needs, including affordable, for the plan area?
 Ensure an appropriate mix of dwelling sizes, types and tenures to meet the needs of all sectors of the community?
 Improve cross-boundary links between communities?
 Provide housing in sustainable locations that allow easy access to a range of local services and facilities?
 Promote the development of a range of high quality, accessible community facilities, including specialist services for disabled and older people?
6.3 We support the above decision-aiding question, but suggest that, in addition to meeting the District’s housing needs (including affordable housing), the Local Plan should seek to improve the affordability of housing for local residents.
6.4 The median house price in the District is 11.57 times the median gross annual workplacebased earnings (‘the affordability ratio’). The affordability of housing has worsened significantly in recent years – and to a much greater extent than the national average. In 2000, the affordability ratio for the District was 5.08 – only slightly worse than the national average of 4.13. By 2020, the national affordability ratio had increased to 7.69 –
significantly below the District’s 11.57.

1.0 Introduction
1.1 These representations are submitted to the Rochford New Local Plan Spatial Options (RLPSO) on behalf of Countryside Properties and in respect of Land at Pulpits Farm, Hockley.
1.2 The Site has previously been submitted in response to the Council’s Call for Sites, and is reference CFS263 in the Council’s plan-making process (although also referred to as Site 272, in the Council’s Green Belt Study (2020))
1.3 This representation should be read alongside the Vision Document that has been prepared in respect of the development of the Site, and which accompanies the
representations as Appendix A.
2.0 Response to Local Plan Spatial Options Question 4
Q4. Do you agree with the strategic priorities and objectives we have identifies? Is there anything missing from the strategic priorities or objectives that you feel
needs to be included?
2.1 We suggest that improving the affordability of housing for local people in Rochford District should form an objective of the Local Plan.
2.2 As the RLPSO rightly recognises at page 12, housing affordability is a particularly issue within the District.
2.3 ONS data on the affordability of housing reports that in 2020 the median house price was 11.57 times the median gross annual workplace-based earnings. The affordability of housing has worsened significantly in recent years, and is substantially worse than the
national average.
2.4 Without an increase in housing supply, we consider there is a very real risk that it will only worsen.
2.5 Not only do current projections suggest increased housing need in the District, but the longer term impact of the Covid-19 pandemic may well place additional pressure on Rochford’s housing market and affordability of homes for local people.
2.6 Early indications are that there has already been an increased desire to move from more to less urban areas, due to a combination of a desire for homes with larger garden areas and home offices, better access to open space, and within less densely populated areas; and people considering it less critical to live very near their place of work, given the increase in home working within a number of employment sectors.
2.7 This is of particular relevance to Rochford District, given that London is accessible via railway services from parts of the District; and house prices are relatively affordable when compared to other areas in and around London.
3.0 Response to Local Plan Spatial Options Question 6
Which of the identified strategy options do you consider should be taken forward in the Plan?
3.1 We consider that a balanced approach that includes direction of a relatively significant proportion of the District’s housing needs to the higher tier settlements (including Hockley) would be the most appropriate strategy, for the reason set out below.
Strategy Option 1 – Urban Intensification
3.2 The RLPSO states that this option would entail making best possible use of our existing planned developments, previously developed land and other under-utilised land, such as vacant buildings and contaminated land; and notes that a strategy based on urban intensification could also include taking a more permissive approach to higher densities in suitable locations (such as town centres and near stations). It is suggested this would involve no loss of Green Belt land, would minimise loss of greenfield, and would deliver
4,200 homes over the next 10 years.
3.3 The RLPSO describes Strategy Option 1 as “the minimum expectation of national policy” and states it is “likely to be required within every strategy option”.
3.4 We agree that it would be consistent with national policy to seek to promote the redevelopment of appropriate previously developed land to help meet development needs. However, we consider that a strategy which were to rely purely on this to meet development needs would be ineffective, unsustainable, incapable of meeting development needs in full as required by national policy, and result in a Local Plan that would be inherently unsound.
3.5 The National Planning Policy Framework (NPPF) confirms (paragraph 35) that one of the requirements of a sound Local Plan is that it seeks to meet the area’s objectively assessed development needs in full. The NPPF also emphasises the Government’s objective to significantly boost housing land supply (paragraph 60).
3.6 However, the RLPSO acknowledges that Strategy Option 1 would fall significantly short of meeting local development needs in full. Not only would this render the plan unsound and contrary to the NPPF, but it would likely result in significant negative social and economic impacts locally.
3.7 In any case, we consider that a yield of 4,200 dwellings over 10 years through urban intensification to be unfeasibly optimistic.
3.8 To achieve this quantum, it would be necessary to sustain an average of 420 dwellings per annum (dpa) over a 10-year period. The Council’s Annual Monitoring Report 2019/20 states that between April 2010 and March 2020, the District achieved a total of 1,768 dwelling completions over this particular 10-year period – an average of just 177 dpa. Furthermore, the delivery of these 1,768 dwellings was not solely through urban
intensification, but also included allocations made through the Rochford Allocations Plan (2014). There is of course only a finite supply of previously developed land that is
suitable and viable for residential redevelopment, and it is considered that much of this has likely already been exhausted, particularly given the emphasis placed by national and local policy on utilising such sites.
3.9 In addition to Strategy Option 1 being unlikely to deliver anywhere near the number of new homes needed in the District, we would also question the appropriateness of such a strategy in any case. To make a meaningful contribution to housing needs over the
plan period, this strategy would likely require development at a significantly greater density than existing development in the District. Not only could this be harmful to the character of the District’s residential areas, but it may also result in loss of amenity for existing residents.
3.10 Furthermore, it is unclear if this approach would deliver the types of homes required where they are required in the District. Such a strategy is, for example, unlikely to deliver a high proportion of family homes.
3.11 For the above reasons, we do not consider that Strategy Option 1 is capable of resulting in a sound Local Plan and should be discounted.
Strategy Options 2, 3 and 4
3.12 Given Strategy Option 1’s inability to result in a sound Local Plan, this leaves Options 2, 3 and 4 as potential strategies.
3.13 Strategy Option 2 is to focus on urban extensions, with Option 2a entailing focussing such growth on the District’s main towns; and Option 2b dispersing to all settlements based on the settlement hierarchy.
3.14 Through Strategy Option 2 sustainable sites could be utilised at the edge of settlements, which should include Hockley, to deliver a range of housing developments, including the provision of much needed housing in the short term. This option provides flexibility to utilise smaller sites to deliver homes earlier alongside larger sites to meet the overall housing need.
3.15 We consider that Strategy Option 2b should include growth to Hockley, given that it is a top tier settlement in the adopted Development Plan’s settlement hierarchy.
3.16 In relation to Option 3, this suggests focussing growth on one of three locations (west of Rayleigh (3a); north of Southend (3b); and east of Rochford (3c)). We consider there is merit to strategic scale growth that can help deliver significant infrastructure improvements. However, this needs to be complemented by the delivery of a range of different sites (including those that can deliver in the short term and do not require
significant infrastructure improvements) and in a range of different locations that reflect the fact that the District comprises a number of distinct settlements with their own
identities and communities, all of which the Local Plan should seek to support.
3.17 The outcome of the Uttlesford Local Plan Examination provdes a warning regarding the dangers of over reliance on large strategic growth sites to meet housing needs. Recommending the submitted plan be withdrawn due to soundness issues, the Inspectors concluded:
“In order to arrive at a sound strategy, we consider that as a primary consideration, the Council would need to allocate more small and medium sized sites that could
deliver homes in the short to medium term and help to bolster the 5 year [housing land supply], until the Garden Communities begin to deliver housing. This would have
the benefit of providing flexibility and choice in the market and the earlier provision of more affordable housing”. (Paragraph 114 of Uttlesford Local Plan Examination
Inspectors’ letter of 10 January 2020)
3.18 This does not of course mean that the strategy cannot include strategic growth allocations, only that if it were to, they would need to be accompanied by a range of other small and medium sized sites.
3.19 Strategy Option 4 entails a mix of the other options, and rightly recognises that the alloction of strategic growth sites and the allocation of urban extensions are not mutually exclusive. We consider this option does have particular merit, and it is notable that it was scored positively by the Integrated Impact Assessment (IIA) in relation to its social, economic and environmental impacts. This option will still allow for current housing
needs to be addressed in the short term, as the Local Plan is required to; as well as enabling provision of strategic allocations if so wished. It will also allow for proportionate growth to be directed to the District’s various communities through settlement extensions, including Hockley – something which we consider is essential for the Local Plan to do if it is to deliver sustainable development.
Hockley
3.20 We consider that, in order for the Local Plan’s spatial strategy to promote sustainable development, to be justified, and to be capable of being found sound, it will be essential for it to direct a proportion of the District’s growth to Hockley.
3.21 Hockley / Hawkwell is identified as a Tier 1 settlement in the current Development Plan, i.e. one of the settlements considered most sustainable to accommodate greatest levels of growth.
3.22 Notwithstanding this, the District has experienced considerably less housing development since adoption of the Core Strategy than the other two Tier 1 settlements.
It is recognised that this is in part due to aspirations for the redevelopment of the town centre not being realised, as conditions have changed; and also partly due to constraints to the settlement’s growth as a result of Hockley Woods and the Upper Roach Valley Special Landscape Area to the south. Nevertheless, there are opportunities to deliver sustainable extensions to the existing settlement, particularly located away from the
more sensitive areas to the south.
3.23 Hockley is an established, vibrant community with a long history. It is important that planning helps support and enhance the vitality of the community, including by directing future growth to the settlement.
3.24 The RLPSO recognises that housing affordability and availability are key issues in Hockley. The Local Plan represents an opportunity to help address this issue, by
directing additional housing to this location. Conversely, failure to direct sufficient housing to Hockley is likely to result in housing becoming increasingly unaffordable for
local people. It is manifestly clear that if the Local Plan is to be a sound plan that meets development needs in a sustainable manner, then it cannot rely on RLPSO Option 1.
Alterations to the Green Belt boundary
3.25 It is evident that the District’s Green Belt boundaries will need to be amended in order to meet development needs and provide a sound plan for the future of the District.
3.26 The NPPF confirms (paragraph 140) that Local Plans are the appropriate vehicle through which to make alterations to the Green Belt boundary.
3.27 The NPPF (paragraph 140 again) also states that such alterations should only be made where exceptional circumstances are fully evidenced and justified.
3.28 Exceptional circumstances are not defined in national policy or guidance.
3.29 However, there is case law which provides a basis for the consideration of the issue. In particular, the judgment in Calverton Parish Council v Nottingham City Council & Ors [2015] EWHC 1078 (Admin) suggests (paragraph 51) that the following matters are relevant in the consideration of whether exceptional circumstances exist to justify alterations to the Green Belt:
 The scale of the objectively assessed need;
 Constraints on supply/availability of land with the potential to accommodate sustainable development;
 Difficulties in achieving sustainable development without impinging on the Green Belt;
 The nature and extent of the harm to the Green Belt; and  The extent to which impacts on the purposes of the Green Belt may be mitigated as far as practicable.
3.30 The District is subject to an acute local housing need. The existing Green Belt boundary
is drawn tightly around the District’s existing settlements, and opportunities to meet development needs are severely restricted without alterations to the Green Belt
boundary.
3.31 Given the scale of objectively assessed need faced by the District, and the lack of potential alternatives to releasing Green Belt in order to sustainably meet such needs, it is evident that there are exceptional circumstances that justify alteration to the Green
Belt through the Rochford Local Plan.
4.0 Response to Local Plan Spatial Options Question 29
Do you agree that the plan should designate and protect areas of land of locally important wildlife value as a local wildlife site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection?
4.1 We agree that the Local Plan should seek to protect areas of locally important wildlife. Furthermore, we consider it should seek to deliver ecological gains.
4.2 However, the designation of such sites must be justified by robust evidence.
4.3 The 2018 Local Wildlife Review suggested a new Local Wildlife Site (R41) which
incorporates some of what is currently Local Wildlife Site R24, along with additional land to the west of this, including part of the Land at Pulpits Farm (CFS263 (‘the Site’).
4.4 The evidence for designating such additional land as a Local Wildlife Site is unclear.
4.5 It is not clear from the 2018 Local Wildlife Site Review what particular characteristics of the land forming part of CFS263 proposed to be designated as a Local Wildlife Site justify this land’s designation as such.
4.6 There is no evidence that a detailed survey of the Site was undertaken as part of the 2018 Local Wildlife Site Review that could justify its inclusion within a Local Wildlife Site.
4.7 The Site has been subject to an ecological constraints and opportunities survey, undertaken in 2020 by qualified specialist ecological consultancy, Southern Ecological Solutions.
4.8 This survey identified that the Site comprises habitats of varying value to biodiversity, with the most suitable habitat at the Site’s boundaries in the form of hedgerows, mature trees, rough grassland margins and watercourses. However, there was nothing to suggest that the Site merits any form of designation for its ecological value.
4.9 A copy of this initial survey is provided as Appendix B to these representations.
4.10 It is not the case that evidence must be provided to set out why the Site should not form part of the Local Wildlife Site. On the contrary, if this land is to be designated as a Local Wildlife Site, it is incumbent upon the Council to provide robust evidence justifying this.
4.11 We do not consider the Site merits designation for its ecological value, and would object to any proposals to do so. However, we do recognise that parts of the Site are of
ecological value. As part of the development of the Site, existing ecological features would be retained and, where practicable, enhanced.
4.12 It is important to recognise that development of land often has the potential to engender ecological benefits, and that would be the case in the development of site CFS263.
5.0 Response to Local Plan Spatial Options Question 58
Q58a. Do you agree with our vision for Hockley and Hawkwell? Is there anything you feel is missing?
5.1 We agree with the vision for Hockley as proposed by the RLPSO.
5.2 In particular, we very much support the objective of improving housing affordability in order to ensure that local first-time buyers can afford to live locally.
5.3 If this vision is to be realised, it will be imperative to provide a sufficient number of new homes for Hockley, and of a variety of types and tenures, to meet all of the community’s needs.
Q58b. With reference to Figure 46 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 Hockley and Hawkwell?
i. Housing
5.4 Land at Pulpits Farm (CFS263, ‘the Site’) is suitable, available, and achievable for residential development as a sustainable extension to Hockley. The Vision Document
which accompanies this representation (Appendix A) sets out details regarding the Site’s ability to sustainably deliver a high-quality development.
5.5 The Site was considered through the Council’s Strategic Housing Land Availability Assessment (SHELAA) (2020). The SHELAA (2020) considered the Site’s suitability in relation to a multitude of constraints, including policy, environmental, ecological, heritage
and physical constraints. In respect of the Site and potential constraints, this assessment concluded:
“Green Belt site that is currently in mixed use with residential and ancillary outbuildings, with some vacant grassland. There is an existing access with no
fundamental constraints to redevelopment of the site” [Emphasis added].
5.6 In summary, the only constraint to the Site’s development identified was its location within the Green Belt in the current Development Plan – a policy constraint.
5.7 In addition, the SHELAA (2020) assessed the Site’s suitability in terms of its accessibility to local services.
5.8 In relation to accessibility alone, it stated:
“There are two bus stops within c 0.3km of the site, however these are served by only two bus routes (No7/18). A private road connects the site to Greensward Lane, a C road which traverses the centre of Hockley before connecting to the wider strategic road network”
5.9 In addition to the points made within the SHELAA (2020) we would add that the Site is c.12 minutes walking distance from Hockley railway station. When considering
accessibility of this Site, and its appropriateness for allocation, this is clearly a key consideration.
5.10 In particular, it is important to note that the NPPF instructs Local Planning Authorities to prioritise sites that have good access to public transport when considering release of Green Belt to meet development needs. At paragraph 142 of the NPPF it states:
“Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previouslydeveloped and/or is well-served by public transport”.
5.11 The Green Belt is drawn tightly around the existing extent of residential development in Hockley. As noted in our response to Question 6, Hockley is clearly a sustainable location to accommodate a proportion of the District’s housing needs, and furthermore it is important that the vitality of Hockley be supported through the direction of sustainable growth to the settlement. It will be necessary to direct some growth to Hockley in order to ensure a sound Local Plan that delivers sustainable development, and to deliver this it will be necessary to alter the existing Green Belt boundary. In making such a revision, sites such as CFS263 which have good access to public transport should be prioritised for residential allocation.
5.12 The SHELAA (2020) considered the Site’s proximity to local services and stated: “A primary school sits c 1km to the east of the site, with a secondary school c 0.6km
to the west. A garden centres [sic] sits within C 0.3km of the site with a small number of shops along Greensward Lane”.
5.13 We consider the above significantly understates the range of local services and facilities that are in proximity to the Site.
5.14 In particular, the SHELAA (2020) appears to have overlooked that the Site is adjacent to
a GP surgery.
5.15 The Site is also well located in relation to a range of other services, facilities, employment opportunities and centres. As set out in the Vision Document that accompanies this representation, the following can be reached without use of a car within the following
journey times:
Walking:
Bus stop 1 minute
Greensward Surgery 1 minute
Greensward Academy Secondary School 5 minutes
Hockley Railway Station 12 minutes
Plumberow Academy Primary School 15 minutes
Convenience retail (Co-Op, Spa Road) 15 minutes
Hockley Post Office 15 minutes
Eldon Way 15 minutes
Approximate centre of Hockley Town Centre 17 minutes
Bus:
Approximate centre of Hockley Town Centre 5 minutes
Rochford Town Centre 14 minutes
Rayleigh Town Centre 16 minutes
Train:
Southend Victoria 27 minutes
London Liverpool Street 60 minutes
5.16 In 2014, sustainable transport charity Sustrans estimated that school traffic contributed,
nationally, to 24% of all traffic at peak times. The accessibility of both primary and
secondary schools from the Site without reliance on a car, and the potential to avoid
additional traffic that might be otherwise generated, is considered to be a factor which
weighs significantly in favour of utilising this Site to help meet housing needs.
5.17 The principal constraint to the Site’s development is that it is currently within the Green Belt.
5.18 In terms of the Site’s contribution to the purposes of the Green Belt, it is relevant to note that is an edge-of-settlement Site, the character of which has been influenced by adjacent residential uses to the north, west and south. The Site is subject to a degree of containment provided by existing features, and its development would not give rise to unrestricted urban sprawl. On the contrary, it would allow for a new, robust Green Belt
boundary to be implemented.
5.19 The Council’s Rochford District and Southend-on-Sea Borough Joint Green Belt Study February 2020 (‘the Green Belt Study (2020)’ concluded that the western portion of the Site could be developed with only moderate harm to the Green Belt. This is before mitigation measures are factored in (which case law suggests must be considered in determining whether exceptional circumstances apply), and once potential measures are
accounted for (such as provision of landscape buffers) it is considered that the Site’s development would not undermine the strategic purposes of the Green Belt.
5.20 Use of the Site to provide market and affordable homes would result in a number of social, economic and environmental benefits, as set out within the Vision Document
(Appendix A). These include, in summary:
 Market and affordable homes to help meet acute local need;
 Highly accessible Site, with opportunities for future residents to access services and facilities without use of a car;
 Efficient use of land which lacks environmental constraints, reducing pressure to develop more sensitive sites to meet needs;
 Provision of variety of public open space across the Site, including informal open space, ponds, structural landscaping for wildlife;
Increased expenditure within the local area, supporting jobs and helping sustain local facilities and services;
 Creation of direct employment during construction, as well as indirect employment related to the supply chain;
 Landscape and ecological enhancements as part of development;
 Development within a location that will help sustain the vitality of Hockley Town Centre.
5.21 It is important that where Green Belt is released for housing, the Council can have confidence that such land will be delivered and contribute to meeting needs.
5.22 In addition to being suitable and sustainable, the Site is also available and achievable for residential development.
5.23 The Site is not subject to any legal or ownership constraints to development.
5.24 The Site is being actively promoted for development by an established housebuilder with a track record of delivery. The Council can be confident that the Site will be deliver, and through a high-quality development, if allocated through the Local Plan.
6.0 Comments on Integrated Impact Assessment
Assessment Framework
6.1 At Table 1.1 of the Integrated Impact Assessment (IIA), the assessment framework is set out. This explains that the objectives of the population and communities theme are
1) to cater for existing and future residents’ needs as well as the needs of different groups in the community; and 2) maintain and enhance community and settlement identity.
6.2 In respective of objective 1, Table 1.1 explains that assessment questions relate to the following:
 Meet the identified objectively assessed housing needs, including affordable, for the plan area?
 Ensure an appropriate mix of dwelling sizes, types and tenures to meet the needs of all sectors of the community?
 Improve cross-boundary links between communities?
 Provide housing in sustainable locations that allow easy access to a range of local services and facilities?
 Promote the development of a range of high quality, accessible community facilities, including specialist services for disabled and older people?
6.3 We support the above decision-aiding question, but suggest that, in addition to meeting the District’s housing needs (including affordable housing), the Local Plan should seek to improve the affordability of housing for local residents.
6.4 The median house price in the District is 11.57 times the median gross annual workplacebased earnings (‘the affordability ratio’). The affordability of housing has worsened significantly in recent years – and to a much greater extent than the national average. In 2000, the affordability ratio for the District was 5.08 – only slightly worse than the national average of 4.13. By 2020, the national affordability ratio had increased to 7.69 –
significantly below the District’s 11.57.