New Local Plan: Spatial Options Document 2021

Dear Sir,
Re: Stakeholder: Reference CP15678E. Community Representative No. 29007.

New Local Plan 2021 Consultation. Issues and Options Documents & Statement of Community Involvement and the Spatial Options documents.

We request Rochford District Council to invite the Government Planning Inspector to find that the New Local Plan 2021 must be withdrawn for reasons mentioned below.
In our consideration the Map A, on the basis of the relevant Legislation Guidance in the National Planning Policy Framework is not:
Positively Prepared
Justified
Effective
Consistent with National Policy

There are sufficient clauses in the NPPF, LDF and Localism Act which stipulate that all issues must be considered including Infrastructure and in areas environmentally threatened as shown in the Environment Agency and the Insurance Company data (Flood maps). It is imperative proper assessments be made in accordance with the NPPF regulations such as Flood, Road Network, Proximity to rivers and all issues set out below. Our experience from the current Malyons Lane large development that our SCI will be ignored again unless we have support from our MP Mark Francois and all the Councillors who are continually proud to state they are Community minded.

The Hullbridge Residents Association have viewed the Local Development Framework Evidence Base and note that the contents are a repeat of the documents issued in 2015 as are the documents mentioned above
Along with the accompanying Integrated Impact Assessment.

Section 1. Introduction
1.1 States this is a review document of the original adoption in 2016, now presented in repetition but revised in 2015 and 2017 (for 2021).

We understand the need for additional homes, but we are concerned that ‘Infrastructure is not given priority as stated by our MP Mark Francois and indeed Government directives, particularly the existing infrastructure but continually being ignored.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

Page 1. Clause 1.2

HRA produced and delivered to RDC a 45-page document on the Core Strategy, Land Development Framework (LDF), National Planning Policy Framework (NPPF) and Localism Act for a development in progress and submitted some 525 issues in the planning documents presented by RDC without a proper response.
The clauses about Community Consultation being important is just a paper exercise to convince the Planning Inspector that the community support all the data produced.

HRA 9 years of experience has shown RDC and Councillors lack of the understanding or interpretation of Community Involvement, proper consultation and transparency, and fear another regretful experience with all sites being put forward for possible development. Having spoken to some Councillors they state that these site will not necessarily be approved to allow planning applications, but past experience does not provide any confidence that the community issues will be taken into account..
We make a plea to the Government Planning Inspector to investigate reasons why the community are ignored in proper consultation.

36 Sites.
We demonstrate our reasons for our rejection of many sites (stated in our document marked “Exhibit B- Issues and Options”) until the subject of the infrastructure (in all aspects- including existing) are reviewed This is an important subject and we extend our Plea to the Planning Inspector to set this review in motion and allow full participation by the Community Representative.

We consider the following clauses of the NPPF and Core Strategy must be applied:

NPFF 3– Core Planning Principles. Pages 1, 5-6, Clauses 1-2, 6-17.
NPPF 4 – Promoting Sustainable Transport.
NPPF 5 – Supporting high quality communications infrastructure. With roads/transport a priority.
NPPF 6 – Delivering a wide choice of high quality homes.
NPPF 7- Requiring Good Design.
NPPF 8 – Promoting Healthy communities.
NPPF 9 - Protecting the Green Belt land.
NPPF 10- Meeting the Challenge of Climate Change, Flooding & Coastal change.
NPPF 11- Conserving and enhancing the future environment.
NPPF Plan Making – Local Plans (p. 37).
NPPF Using a Proportionate evidence base- (p. 38).
NPPF Ensuring Viability and Deliverability- ( p. 41).
NPPF Decision taking – Pre-application engagement & front loading, (p. 45).
Technical Guidance to the NPPF- Flood risk on page 2. Sequential and Exceptional Tests p. 3 to 7.
NPPF - Sequential and Exceptional Tests –

Drainage
Sustainable drainage systems;
We have submitted documents in respect of the existing drainage system needing substantial improvements prior to any links being provided to the new developments and should be part of the necessary required Infrastructure works we have continually highlighted that the present system is not ‘fit for purpose’, but this was ignored. RDC are duty bound to inform ECC (RDC state that this is not their responsibility.


Stakeholder Ref: CP15678E Community Representative Ref: 29007


Page 2.
Clause 1.7 Statement of Community Involvement.
Having been disappointed with the first Statement of Community Involvement document in 2013 and 2016 we take the clause 1.7 on page 2 seriously and look forward to proper ‘consultation’ by RDC, and not use our submission purely as a ‘tick-box’ exercise to prove to the Planning Inspector that the regulations are observed and, our views have been taken into account but we have not seen these issues progressed to amendments in the Local Plan. HRA represent the Hullbridge community and have the right for engagement as stated in the NPPF and the Localism Act.

Clauses 1.8 & 1.9.
A plan indicating 36 additional sites on Map A in Hullbridge along with a further 6 sites not identified on Map A. Please refer to our Exhibit A on pages 14 and 15.

Clause 1.10 is of special interest as it mentions “on-going consultation” at every stage. We did not have the opportunity to discuss ‘The Draft Scoping Report’ which was published on the RDC websites, and the residents, businesses and other ‘stakeholders’ on the RDC mailing list were not consulted (HRA is a Stakeholder and Representative)- continually ignored by RDC- indeed HRA have correspondence relating to this issue that “if we did not like it we should consider litigation’.

Clause 1.14 on page 4 is of special interest to us as we placed emphasis on the Localism Act (2011) with the Managing Director of RDC and were told that the Localism Act was irrelevant. Why is it now more relevant than before? We request this ‘Act’ to be included as it supports Human Rights.

Clause 1.16. Only one ‘drop-in session’ was set up at Hullbridge Community Centre on 24/8/21. The attendance was low, HRA committee had 9 committee members present who asked questions and had responses which do not reflect the issues put forward in this ‘Plea’. One answer took us by surprise, that the Essex Design Guide which we have referred to throughout has been replaced by Rochford own Design Guide. When we consider the reduced staff levels with some unqualified planning staff it leads us to believe that this design guide will be subject to much criticism. We hope the Government Inspector will take this into account.

Planning law requires that “Call for Sites” which falls part of the development plan in accordance with the Regulations Governing Neighbourhood Planning Laws- NPPF 6 - Plans and Strategies – Part 6, Chapter 1, clauses 109 to 113, allows for Neighbourhood Planning – Part 6, chapter 3, clauses 116 to 121., and gives the community the right to Consultation – Part 6, chapter 4, clause 122. We challenge RDC to approve our application for this Neighbourhood Planning Group and a Statutory Consultee status which will also be an asset to the Hullbridge Parish Council. No explanation is given for reasons why we are not allowed to have consultation to give us good reasons why the regulations are not being properly debated and a conclusion found. This attitude denies community skills and professions adequately proven over 9 years of hard work, not acknowledged.

The four principles that follow imply that the core strategy should be relevant, sustainable and ‘Fit for Purpose’ and become part of the NPPF and LDF:
• Positively prepared.
Our observation on the previous Local Plan that insufficient forward planning had been carried in accordance with the Core Strategy which should have been adhered to and we will not be surprised if the same ‘policy’ will prevail. We look forward to the Planning Inspector requesting a coordinated approach and consultation with the community representatives, as the present system is not fit for purpose.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

• Justified.
In view of the aforesaid we do not believe there was any justification to allow more sites to be put forward without clear thinking on assessments being made in respect of the “existing Infrastructure”, and the use of Green Belt land being used instead of Brownfield land and the other issues stated in this document.
The Core Strategy, NPPF and LDF and Localism Act all express that Green Belt land should only be used as a last resort and only under exceptional circumstances, many issues which we have demonstrated have not been addressed sufficiently. Can RDC demonstrate why they are unable to adhere to the rules and regulations designed to safeguard the community.
According to the Localism Act 2011, we have demonstrated that transparency and consultation were lacking with the community. This has to be rectified and included within the proposed Local Plan.
• Effective
The conditions for the development of the 36 Hullbridge sites will not be satisfied for the reasons given above, therefore we consider a complete review of these possible proposed developments and the Core Strategy allows for the community to raise these issues and get into meaningful dialogue with RDC.
• Consistent with National Policy
National policy insists that all the policies stated should be transparent, proper consultation pursued in relations to all the development criteria. We do not believe that proper feasibility studies, risk analysis have been conducted in order to satisfy the requirements of the NPPF and LDF. Most subjects referred to in this presentation will imply reasons for withdrawal, in view of Government directives and regulations listed above.
The Localism Act 2011 Chapter 20. suggested meaningful dialogue with the HRA. Our residents asked what guarantees will be given to HRA that we will be listened to, not merely placing this document on RDC website to satisfy the Planning Inspector requirements. We require RDC Planning/Legal department to clarify.

Clauses 1.18 and 1.19 speaks of ‘community-led planning’ which is of interest to HRA but all our applications and requests for clarification are ignored. We have consistently placed great emphasis on ‘community cohesion’. Which makes for good public awareness. We can produce correspondence to the Parish Council for cohesion in respect to the whole community and help to remove the divisions which exist at present.
HRA have requested support from the Hullbridge Parish Council and indeed our rights should be upheld in accordance with the Localism Act..

Page 5.
Clauses 1.20 and 1.21
How can the RDC ensure that our proposals can be supported for the benefit of the community.
Clause 1.21 Infrastructure Delivery Plan (IDP) and the Community Infrastructure Levy (CIL) will be prepared to set out the circumstances that the CIL will be applied and the key infrastructure that the CIL will seek to fund. The Council will seek to fund this through a ‘Community levy’. This implies that the RDC are not protecting the community. ECC financial planning administration needs reviewing on the subject of ‘contingencies’ which should apply to all categories of infrastructure and other important categories to allow for future planning, maintenance and improvement.

The Essex County Council document “Greater Essex Growth” states that Greater Essex Growth and Infrastructure Framework 2016 is not listed or discussed. The Executive Summary says that Section 106 and ‘Community Infrastructure Levy’ (CIL) will fall way short of expectations and other Government Funding will be in ‘shortfall’ to the tune of £ Billions (report produced by AECOM) who also produced the RDC “Sustainability Analysis”, please explain why they did not cite this issue.
Stakeholder Ref: CP15678E Community Representative Ref: 29007

HRA study of funding under section 106, particularly to fund the local Clinics (£164k recently) which was put to the NHS and RDC fell short of the required sum in view of the increased population. HRA requested consultation to allow co-ordinated conclusions. No surprise this was ignored by all concerned.
The normal LA practices are that a 10 year plan allowing the income to be divided into categories of funding allowing for contingencies for each element of Infrastructure to satisfy needs as they arise, so the question is what have you done with those budgets, as we keep being informed of shortage of funds, perhaps the auditors are allowed to explain how that money was spent. We ask, under ‘The Freedom of Information Act’ why the Hullbridge infrastructure was allowed to deteriorate over at least 50 years.
HRA object to the IDP and CIL because these should be RDC, ECC and Agency obligations to use the contingency funds and not produce more rules which allow the LA to cover up their own accountability inadequacies and should not be an ‘extra’ burden to the community.
If approved, this will set a precedent for other forms of funding from the communities. The community are concerned by this new statement lacking in the Core Strategy and the Land Development Framework. Can you blame the community for showing concern that LA mismanagement of funds fall to the communities having to make good the shortfall wherever they occur.

Page 9. Item 3.2. 36 Sites additional development Land.
The Land Mass measured and stated in this clause we find is out of date because several hectares have already been built on since 2012 which should have been taken into consideration, thus reducing the Land Mass area. Your review and consultation is necessary and we look forward to open discussions in
accordance with the Localism Act.

Section 3. Please refer to our Exhibit A- Development density comparison on pages 14/15.
The total measure of 36 sites = 124 hectares (approximately) which will provide a capacity of 3720 dwellings at minimum 30 dwellings per hectare. The minimum density of 30/60 dwellings per hectare can provide 3720 to 7440 dwellings.

Boundary Line.
Further examination of the same map A indicates that 30.5% of the land lies in the adjoining Rawreth Parish. Please refer to our Exhibits A and B on pages 14-15 and 16 – 20 consecutively.
The result provides the following information:
In our examination of the New Local Plan Document, we are unable to find any explanation for dealing with this ‘division’. Using our previous submission in relation to the Boundary Line indicated on the Ordnance Survey shown and confirmed by the Local Boundary Commission, our correspondence with Rochford District Council requesting clarification on the Parish Council division and the financial implications, they refused to accept the existence of this Boundary line. At a meeting with the developer, we were informed that RDC will allow Council Tax collected by Hullbridge on behalf of Rawreth Parish. Have RDC made the necessary application to LBC for the necessary changes to the Boundary Line and whether or not Rawreth will be amalgamated with Hullbridge at some future date.
The same principle applies with the Boundary Commission England and the National Planning Policy Framework regulations, again we ask for specific dialogue to satisfy the regulations. One of the Green Belt policy purpose is to prevent neighbouring towns/villages from merging into one, Can RDC explain why they seem to have abandoned this policy.

Page 10. Clauses 3.6 to 3.8, Figures 2 and 3. “Travel to work outflows and inflows”.
The travel patterns have changed since 2011 by about 18% with the increase of population. We request a review of the information being given, affecting transport congestion and lack of proper infrastructure.

Page 11. Clauses 3.9 to 3.12. Employment statistics.
We suggest a review is necessary. What guarantees will the prospective developers give to employ local skills.
Stakeholder Ref: CP15678E Community Representative Ref: 29007

Pages 12 and 13. Our Environment. Clause 3.13
Previous Statements made by the Environment Department, Highways & Water Agencies and the HSE suggesting assessments made in 2011 and 2014 were ‘insufficient’ and all future assessments will also fall short of efficiency with funding being used as an excuse to minimise costs giving rise to lack of obligations to this community and to blame Government pressure to satisfy the development quota being used as an excuse to limit the scale of assessments, thus breaching the clauses in the LDF, NPPF and Localism Act.
The same agencies gave evidence to the Planning Inspector that Hullbridge is a ‘sparsely populated’ area. This can be classified as a false statement knowing that Flood water has been a major concern for many years including surface and foul water discharges onto roads and gardens, due to lack of improved drainage facilities and gardens constantly under water. Further land being put forward for development will exacerbate the infrastructure issue. We are informed that RDC do not keep records of ‘Public health’ issues, any complaints are ignored. Foul sewers are grossly overloaded. A full upgrade of the drainage system has always been overdue. This issue should be investigated rigorously by the RDC and it is their responsibility to inform the ECC.

Page 14. Our Communities.
The Hullbridge population count for 2011 census states a population of 6858. HRA support from the community in 2017 suggests 7000 and in 2019 = 7400.
The current development of 500 homes proves an annual population increase from 2019 to 2023 = 9400 population. The growth in the previous 3 decades (census) indicated an average of 2.2% increase. This indicates an average annual increase of 2% per census. This is contrary to the Core Strategy, LDF and the NPPF and the Localism Act that any increase in population should follow the historical line. Hopes rise for a new climate of close Community Consultation.

Page 15 Table 1. Breakdown of 2011 Population Census.
These possible developments will increase the Hullbridge population (see Exhibit B- Population) to 35,900 which will be close to the present Rayleigh population within 15 to 20 years.

Hullbridge, presently with a ‘village status’ will become a Town with a population probably second only to Rayleigh. The Portfolio Holder (Councillor Ian Ward) stated that the Local Plans have changed and it was now paramount to ‘listen’ and closely ‘consult and engage’ with the community, but most people are sceptical that our voices will be heard, and the necessary amendments put forward by the HRA ‘professionals’ will not be heeded. Hullbridge presently consider all verbal utterances are not considered in favour of the community, and no changes are evident except for many of our issues on planning which HRA had to investigate without any RDC help to satisfy the community q & a meetings.

Clause 3.20 Using HRA figures given above we are unable to reconcile with your statement that “the proportion of residents in all demographic ranges will remain ‘stable’. We advise the RDC to review their information and observe the contents of our Exhibit A and B on pages 14/15 and 16-21 provides the necessary calculation, showing exceptional over-population.

Page 16
Clauses 3.21 to 3.25 needs to be reviewed in respect of the statements made being out of date, as the document is prepared using data prescribed in 2011 without fact-finding surveys being conducted to carry out ‘forward planning’ especially with the owner-occupation criteria becoming financially unreliable. With experience of the Public Finance Initiative (PFI) being suspect it will be necessary to return to Council House Building with participation between Local Government and Housing Associations being a prime ‘home provider’ but all motives are suspect.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

Section 4
Page 17 – Spatial Challenges.
Great emphasis is placed on the laws governing the National Planning Policy Framework. We highlight the following to allow you to respond to the Hullbridge Residents Association.
We request you uphold the clauses requiring Consultation with the community Representative such as the HRA with and allowing replies to issues of importance to the community, before finalising the New Local Plan.

Consultative Objections.
We submit our “Consultative Objections” and conform to the NPPF policy namely – that the Local Authority and the ‘Applicants’ must work closely with those directly affected by their proposals to evolve designs that take account of the views of the community.

Brownfield and Greenfield land.

The allocation DPD Document (Feb 2010)- Discussion & Consultative Document on page 1 states that the Council Statement of Community Involvement is committed to Regulations 25 Public Participation in the preparation of Planning for the District (revised 2017). We ask for the right to be properly consulted on this issue that the allocation document has no brownfield sites identified as given in our Exhibit B.

Section 5.
Page 24. Clause 5.1. Our Vision and Strategic Objectives.
HRA experience gained over 9 years of deliberations over the Hullbridge ‘developments’ and Local Plans, that this has not been a success as the majority of the 185 issues submitted in 2014, not being satisfied, and with alliances formed with other localities the same view is expressed. The fact that you did not respond indicates that we are right on all the issues submitted to you and hope the Planning Inspector will take this into account in respect of all future “Consultation”.
We hope that the Planning Inspector takes into account the atmosphere of distrust by the community.

Clause 5.4 Our current Vision
HRA disagree that what is being prescribed on the Hullbridge Plan will allow the community to have the best quality of life, when there is at least 20 years of disruption to look forward to, which will blight our lives. Whole sale development is taking place with major clauses in the NPPF being disregarded.
A “Considerate Contractor Scheme Notice must be a requirement for all contractors to observe the rules towards the community.

Page 26. Clause 5.10. Rochford District 2037. Our Society
We disagree with the statement made that’ the green infrastructure network across the district has been enhanced to support our population. Many hectares of Green Belt Land are being allowed to be developed disregarding all the clauses which are supposed to protect the Green Belt and Government directives. Articles written by the Campaign to Protect Rural England (CPRE) bear witness to the contrary and the community remain sceptical about the final outcome.
The community believe that the homes will be for the over- burgeoning populace of London, not of Essex. We fail to see how you can demonstrate the indigenous population expansion taking priority.

Page 28. Cl. 5.11. Strategic Objective 13. Flood.
Experience gained by the lack of proper assessments on flood, disregarding all the issues provided to you in 2013. Decisions are being made according to financial constraints.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

RDC now have a recipe for disaster in an area naturally susceptible to surface water discharge from the ‘Rayleigh Heights’ about 65m above ground level and surrounding areas of vulnerable Watery Lane.


Page 29. Strategic Priority 5. Climate change.
The Hullbridge community are concerned that the information provided by various Agencies and Insurance Companies that the 1:100 flood incident is flawed and is more likely to be a maximum 1:25 due to Climate change. There is scepticism that the LA will help change the law and this will be detrimental to the community at large. Sea levels have officially been recorded as rising some 150mm above sea level from the beginning of this century and are forecast to rise by 500mm before the end of this century.

Section 6.
Pages 32 to 38. Clauses 6.8 to 6.29. Tables 2 to 4.
Advance notice. Property Insurance.
The potential Property Insurance costs against ‘flood risk’ and ‘subsidence in these areas, can range from £2500 to £5000. per household depending on the risk analysis.
An exercise on Post Codes SS5 reveals that using the ‘Hawkeye’ system determining the level of associated risks such as flood, subsidence etc., the combined results show that in both instances, subsidence is Red, meaning these are perils which will either be excluded or a large excess applied in respect of subsidence – usually £2,500.00 (£1000.00 being ‘Standard’) and for any areas susceptible to flood, without protection barriers or flood defences will increase the Cost Risk to £5,000.00 per property making ‘flood excess’ a priority and no claims accepted by the Insurance Companies if this is applied to development in flood areas.

Page 38 to 40. Clauses 6.29 to 6.33. Homes for purchase and Affordable Homes.
This document was obviously written before the changes which have taken place in the financial industry and Government policies. The change in ‘affordability’ has not been fully considered. We advise you to review and amend this statement accordingly.
How can you demonstrate the ‘affordability’ during this financial climate, which are likely to continue for the next 10 years, irrespective of the incentives given on stamp duty and directives to the lending institutions? Most younger adults will have great difficulty to purchase homes and maintain mortgage payments.

Table 5 Rochford District- Settlement Hierarchy.
We have always had an issue with the infringement of the Green Belt. Most of the present developments recently completed or under construction are being built on Green Belt land disregarding brownfield sites. We suspect that the new Land Development Framework document questions the need to build on the green belt land. Our Exhibit B presents you with our statements on your LDF

Page 45. Clause 6.48. Housing Density Options .
Earlier we provided calculations for the lowest density of development per hectare, It is evident that the option may be for up to 60 homes per hectare which will increase the incentive provided by the Government and risk the long term harmony in the community and will cause even greater strain and stress on the Hullbridge infrastructure and the community.
RDC must take advantage of requesting funds from the Government announcement of £866m funds from the Housing Infrastructure Fund (HIF) to enable the existing Hullbridge infrastructure be brought up to standard, on the grounds that the previous planning regime’s over the last 30 years have been negligent in dealing with the existing infrastructure as suggested on page 6. Clause 1.21.



Stakeholder Ref: CP15678E Community Representative Ref: 29007


Section 8.
Local Highways Capacity and Infrastructure. Clause 8.3 LDF Development Management Submission Document- Section 5- Transport page 73. Improvements to local road network
The only access points to get to Hullbridge is Lower Road and Hullbridge Road. Watery lane should not be considered as a main thoroughfare and we despair that the Essex County Council, Rochford District Council and the Agencies seem to ignore this fact. We want the Planning Inspector to review his statement in the ‘Planning approval’ given in 2014 that RDC consult with HRA on the feasibility for improvement of this Lane, as it is not ‘fit for purpose’.

Highways Risk Analysis.
HRA are concerned that a proper Highways Risk Analysis has not been carried out by the Core Strategy, NPPF and LDF documents. Further consideration must be given for ‘transparency’ as stated in The Localism Act (2011). Recent replacement of 50 years old Gas services emphasises the disruption which
will be caused by both existing and future construction work. County and Local Authorities please take note.

Watery Lane, is in urgent need of improvement and HRA have corresponded with RDC, ECC and all the Agencies showing Watery Lane and Hullbridge Road are identified as traffic congestion points, in clauses 8.13 to 8.15.
We request that RDC/ECC/Agencies contact the SAT NAV services to remove Watery Lane as a general thoroughfare and emphasise this is “weight restricted” and ‘width restrictive’ and speed limits reviewed with adequate signage..
This lane is too narrow for any vehicles over 30 cwt. The lane is without a public footpath making this lane a health and safety issue which needs urgent rectification. HRA suggest that this section of the document should be reviewed, particularly as the Planning Inspector acknowledged HRA argument that Watery Lane is not ‘fit for purpose’, we reject the statement that Watery Lane is NOT part of the “Strategic Highways Network” please review, amend and highlight for the Planning Inspector to view..

Accessibility to Services. Hullbridge has many un-adopted, single lane and unmade roads making access difficult for the Fire, Police, Refuse, Ambulance and general delivery services and will not be suitable for constant construction site traffic for next 20 years a covenant should be inserted to allow the ECC and their Agencies to make urgent contingencies before the matter gets worse as expansion proceeds..

Fire Hydrants. Hullbridge only has 8 Fire Hydrants to serve the whole village, which is considered inadequate for the fire services.


Page 85 - 90. Clause 8.22 to 8.37. Sustainable Travel.
The transport system is being overhauled to reduce the number of buses serving the communities and the frequency, if this carries on, there will be future major problems. Please refer to LDF Allocations Submission Document Page 60 Cl 3.177/178.

Page 87. Clause 8.31 Rayleigh Air Quality.
Reading this clause we are not confident that something will be done to provide good quality air. It was reported in the media, that dangerous levels of nitrous oxide caused by diesel fumes are being recorded in and around the Rayleigh area. Air quality is lacking in both depth and detail which means the RDC ‘evidence base’ on the subject of traffic, is lacking. Please explain your remedy? This pollution has been apparent for many years but ignored. The community now demand action to remedy this issue.

Stakeholder Ref: CP15678E Community Representative Ref: 29007


Page 92 to 96. Clause 8.45 to 8.58. Water and Flood Risk management.
Flood
At times of flood (frequent - 25 times in 5 years), in Watery Lane, has resulted in many accidents, causing ‘gridlock’ to the whole local traffic system in Hullbridge and surrounding areas. Drainage is unable to cope with excess flood water resulting in overflow of excrement and water into roads and gardens and cross-surging foul water and surface water services

Page 96- 98. Clause 8.59 – 8.66. Renewable Energy Generation.
We agree about the ‘renewable energy’ ‘dream’ from all sources and accept there is natural course of events to be taken for the sake of the concerns on Global Environment. It is the political challenges which become the difficult part to address. Perhaps Political will may help.

Page 98-100. Clause 8.67- 8.75. Planning Obligations and Standard Charges.
Local Authorities ignore the observations and pleas made to review and observe the standards laid down by the NPPF, Core Strategy and LDDF to allow ‘proper’ consultation with the community representatives.
The NPPF guidelines on all planning obligations suggest that the 3 tests as set out, must pass:
1 Necessary to make the development acceptable in planning terms.
2 Directly related to the development.
3 Fairly and reasonable related in scale and kind to the development.
The community want an action plan to allow meaningful consultation with the community.

Section 9 Supporting Health, Community and Culture.
Page 101- 120. Clauses 9.1 – 9.61. Health Impact assessment- Cl 3.186
We (HRA) brought to the authorities’ attention various anomalies in the financial accountability in assessing the “Contributions” without giving considerations to contingency for increases in inflation and time related uplift. HRA are happy to be consulted in the future.
HRA investigated the Health Provision indicated in Section 106 ‘contributions and concentrated on the sum stated to be for the Riverside Medical Centre on Ferry Road and found the sum stated to be inadequate. We fear the same decisions may be made for the foreseeable future. As HRA have been active on this issue it would be in the interests of all parties to consult and agree a course of action.

Section 10 Protecting and Enhancing our Environment.
Page 121 - Clause 10.1 to 10.4
General planning policy of the NPPF suggests minimising vulnerability and provide resilience to climate change impacts. RDC and ECC must provide a course of actions.

Page 121 – 141. Clause 10.5 – 10.72 Green Belt
We agree the purposes of the NPPF clause 10.7-10.8 in that the 5 purposes of the Green Belt set out to:
1. Check the unrestricted sprawl of large built up areas
2. Prevent neighbouring towns merging into one another.
3. Assist in safeguarding the countryside from ‘encroachment.
4. Preserve the setting and special character of historic towns.
5. Assist in urban regeneration, by encouraging the recycling of derelict and other urban land ie Brownfield Sites. Inappropriate development. (Page 122. Clause 10.8) Specifically states that the construction of new buildings in the Green Belt is generally considered to be inappropriate development.
The Hullbridge Residents Association respectively request that Rochford District Council adhere to these policies and review the New Local Plan Document. It may be appropriate to classify this as “Special Measures” and allow the intervention of a Planning Inspector to adjudicate.

Stakeholder Ref: CP15678E Community Representative Ref: 29007

Section 11. Detailed Policy Considerations. Pages 142- 165
Page 142. Clause 11.2 Mix of Affordable Homes

In HRA discussions with a developer we were advised that the RDC stated that the Core Strategy and the Land Development Framework were ‘out of date’ therefore some clauses were not applicable.
The same situation applied to discussions when applied to the Localism Act. The Core Strategy and the NPPF are evident in many statements in this new Local Plan document, so, we consider there has been no change in the above main documents, action is necessary.

Page 155. Clause 11.45 Brownfield Sites. HRA have taken into account clauses 11.45/ 46 and taken into consideration that all Brownfield sites must have priority. NPPF paragraph 89 and Policy DM10 on brownfield development should be an over-riding factor when producing these documents. We refer you to the ‘ambitious’ clauses stipulated in the LDF Management Submission Document- Clause 3 page 33- The Green Belt and Countryside – Vision. Short term. The first paragraph stipulates the “openness and character” of the Rochford Green Belt continues to be protected. Constant reference by our MP Mark Francois has been ignored which places him in an awkward position.

Page 164. Contaminated land. Cl 11.77 to 11.81. Specific example of for
Nevendon Yard Breakers Yard, Lower Road, Hullbridge. Proposed 90 units.
This site is contaminated over a 70 year period and the costs of eradication will be high. The outline application plans are presently delayed for that reason while a historical document is being prepared.

LOCALISM ACT 2011 chapter 20. Item 2.1 (5th bullet point)
The ‘Localism Act’ was brought into force in 2011, the community did not have the opportunity to apply the clauses of this act. This act stipulates that the Local Community has: the ‘right to challenge’ (Part 5, Chapter 2, Clauses 81 to 86).


End of Appeal For Withdrawal.

Dear Sir,
Re: Stakeholder: Reference CP15678E. Community Representative No. 29007.

New Local Plan 2021 Consultation. Issues and Options Documents & Statement of Community Involvement and the Spatial Options documents.

We request Rochford District Council to invite the Government Planning Inspector to find that the New Local Plan 2021 must be withdrawn for reasons mentioned below.
In our consideration the Map A, on the basis of the relevant Legislation Guidance in the National Planning Policy Framework is not:
Positively Prepared
Justified
Effective
Consistent with National Policy

There are sufficient clauses in the NPPF, LDF and Localism Act which stipulate that all issues must be considered including Infrastructure and in areas environmentally threatened as shown in the Environment Agency and the Insurance Company data (Flood maps). It is imperative proper assessments be made in accordance with the NPPF regulations such as Flood, Road Network, Proximity to rivers and all issues set out below. Our experience from the current Malyons Lane large development that our SCI will be ignored again unless we have support from our MP Mark Francois and all the Councillors who are continually proud to state they are Community minded.

The Hullbridge Residents Association have viewed the Local Development Framework Evidence Base and note that the contents are a repeat of the documents issued in 2015 as are the documents mentioned above
Along with the accompanying Integrated Impact Assessment.

Section 1. Introduction
1.1 States this is a review document of the original adoption in 2016, now presented in repetition but revised in 2015 and 2017 (for 2021).

We understand the need for additional homes, but we are concerned that ‘Infrastructure is not given priority as stated by our MP Mark Francois and indeed Government directives, particularly the existing infrastructure but continually being ignored.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

Page 1. Clause 1.2

HRA produced and delivered to RDC a 45-page document on the Core Strategy, Land Development Framework (LDF), National Planning Policy Framework (NPPF) and Localism Act for a development in progress and submitted some 525 issues in the planning documents presented by RDC without a proper response.
The clauses about Community Consultation being important is just a paper exercise to convince the Planning Inspector that the community support all the data produced.

HRA 9 years of experience has shown RDC and Councillors lack of the understanding or interpretation of Community Involvement, proper consultation and transparency, and fear another regretful experience with all sites being put forward for possible development. Having spoken to some Councillors they state that these site will not necessarily be approved to allow planning applications, but past experience does not provide any confidence that the community issues will be taken into account..
We make a plea to the Government Planning Inspector to investigate reasons why the community are ignored in proper consultation.

36 Sites.
We demonstrate our reasons for our rejection of many sites (stated in our document marked “Exhibit B- Issues and Options”) until the subject of the infrastructure (in all aspects- including existing) are reviewed This is an important subject and we extend our Plea to the Planning Inspector to set this review in motion and allow full participation by the Community Representative.

We consider the following clauses of the NPPF and Core Strategy must be applied:

NPFF 3– Core Planning Principles. Pages 1, 5-6, Clauses 1-2, 6-17.
NPPF 4 – Promoting Sustainable Transport.
NPPF 5 – Supporting high quality communications infrastructure. With roads/transport a priority.
NPPF 6 – Delivering a wide choice of high quality homes.
NPPF 7- Requiring Good Design.
NPPF 8 – Promoting Healthy communities.
NPPF 9 - Protecting the Green Belt land.
NPPF 10- Meeting the Challenge of Climate Change, Flooding & Coastal change.
NPPF 11- Conserving and enhancing the future environment.
NPPF Plan Making – Local Plans (p. 37).
NPPF Using a Proportionate evidence base- (p. 38).
NPPF Ensuring Viability and Deliverability- ( p. 41).
NPPF Decision taking – Pre-application engagement & front loading, (p. 45).
Technical Guidance to the NPPF- Flood risk on page 2. Sequential and Exceptional Tests p. 3 to 7.
NPPF - Sequential and Exceptional Tests –

Drainage
Sustainable drainage systems;
We have submitted documents in respect of the existing drainage system needing substantial improvements prior to any links being provided to the new developments and should be part of the necessary required Infrastructure works we have continually highlighted that the present system is not ‘fit for purpose’, but this was ignored. RDC are duty bound to inform ECC (RDC state that this is not their responsibility.


Stakeholder Ref: CP15678E Community Representative Ref: 29007


Page 2.
Clause 1.7 Statement of Community Involvement.
Having been disappointed with the first Statement of Community Involvement document in 2013 and 2016 we take the clause 1.7 on page 2 seriously and look forward to proper ‘consultation’ by RDC, and not use our submission purely as a ‘tick-box’ exercise to prove to the Planning Inspector that the regulations are observed and, our views have been taken into account but we have not seen these issues progressed to amendments in the Local Plan. HRA represent the Hullbridge community and have the right for engagement as stated in the NPPF and the Localism Act.

Clauses 1.8 & 1.9.
A plan indicating 36 additional sites on Map A in Hullbridge along with a further 6 sites not identified on Map A. Please refer to our Exhibit A on pages 14 and 15.

Clause 1.10 is of special interest as it mentions “on-going consultation” at every stage. We did not have the opportunity to discuss ‘The Draft Scoping Report’ which was published on the RDC websites, and the residents, businesses and other ‘stakeholders’ on the RDC mailing list were not consulted (HRA is a Stakeholder and Representative)- continually ignored by RDC- indeed HRA have correspondence relating to this issue that “if we did not like it we should consider litigation’.

Clause 1.14 on page 4 is of special interest to us as we placed emphasis on the Localism Act (2011) with the Managing Director of RDC and were told that the Localism Act was irrelevant. Why is it now more relevant than before? We request this ‘Act’ to be included as it supports Human Rights.

Clause 1.16. Only one ‘drop-in session’ was set up at Hullbridge Community Centre on 24/8/21. The attendance was low, HRA committee had 9 committee members present who asked questions and had responses which do not reflect the issues put forward in this ‘Plea’. One answer took us by surprise, that the Essex Design Guide which we have referred to throughout has been replaced by Rochford own Design Guide. When we consider the reduced staff levels with some unqualified planning staff it leads us to believe that this design guide will be subject to much criticism. We hope the Government Inspector will take this into account.

Planning law requires that “Call for Sites” which falls part of the development plan in accordance with the Regulations Governing Neighbourhood Planning Laws- NPPF 6 - Plans and Strategies – Part 6, Chapter 1, clauses 109 to 113, allows for Neighbourhood Planning – Part 6, chapter 3, clauses 116 to 121., and gives the community the right to Consultation – Part 6, chapter 4, clause 122. We challenge RDC to approve our application for this Neighbourhood Planning Group and a Statutory Consultee status which will also be an asset to the Hullbridge Parish Council. No explanation is given for reasons why we are not allowed to have consultation to give us good reasons why the regulations are not being properly debated and a conclusion found. This attitude denies community skills and professions adequately proven over 9 years of hard work, not acknowledged.

The four principles that follow imply that the core strategy should be relevant, sustainable and ‘Fit for Purpose’ and become part of the NPPF and LDF:
• Positively prepared.
Our observation on the previous Local Plan that insufficient forward planning had been carried in accordance with the Core Strategy which should have been adhered to and we will not be surprised if the same ‘policy’ will prevail. We look forward to the Planning Inspector requesting a coordinated approach and consultation with the community representatives, as the present system is not fit for purpose.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

• Justified.
In view of the aforesaid we do not believe there was any justification to allow more sites to be put forward without clear thinking on assessments being made in respect of the “existing Infrastructure”, and the use of Green Belt land being used instead of Brownfield land and the other issues stated in this document.
The Core Strategy, NPPF and LDF and Localism Act all express that Green Belt land should only be used as a last resort and only under exceptional circumstances, many issues which we have demonstrated have not been addressed sufficiently. Can RDC demonstrate why they are unable to adhere to the rules and regulations designed to safeguard the community.
According to the Localism Act 2011, we have demonstrated that transparency and consultation were lacking with the community. This has to be rectified and included within the proposed Local Plan.
• Effective
The conditions for the development of the 36 Hullbridge sites will not be satisfied for the reasons given above, therefore we consider a complete review of these possible proposed developments and the Core Strategy allows for the community to raise these issues and get into meaningful dialogue with RDC.
• Consistent with National Policy
National policy insists that all the policies stated should be transparent, proper consultation pursued in relations to all the development criteria. We do not believe that proper feasibility studies, risk analysis have been conducted in order to satisfy the requirements of the NPPF and LDF. Most subjects referred to in this presentation will imply reasons for withdrawal, in view of Government directives and regulations listed above.
The Localism Act 2011 Chapter 20. suggested meaningful dialogue with the HRA. Our residents asked what guarantees will be given to HRA that we will be listened to, not merely placing this document on RDC website to satisfy the Planning Inspector requirements. We require RDC Planning/Legal department to clarify.

Clauses 1.18 and 1.19 speaks of ‘community-led planning’ which is of interest to HRA but all our applications and requests for clarification are ignored. We have consistently placed great emphasis on ‘community cohesion’. Which makes for good public awareness. We can produce correspondence to the Parish Council for cohesion in respect to the whole community and help to remove the divisions which exist at present.
HRA have requested support from the Hullbridge Parish Council and indeed our rights should be upheld in accordance with the Localism Act..

Page 5.
Clauses 1.20 and 1.21
How can the RDC ensure that our proposals can be supported for the benefit of the community.
Clause 1.21 Infrastructure Delivery Plan (IDP) and the Community Infrastructure Levy (CIL) will be prepared to set out the circumstances that the CIL will be applied and the key infrastructure that the CIL will seek to fund. The Council will seek to fund this through a ‘Community levy’. This implies that the RDC are not protecting the community. ECC financial planning administration needs reviewing on the subject of ‘contingencies’ which should apply to all categories of infrastructure and other important categories to allow for future planning, maintenance and improvement.

The Essex County Council document “Greater Essex Growth” states that Greater Essex Growth and Infrastructure Framework 2016 is not listed or discussed. The Executive Summary says that Section 106 and ‘Community Infrastructure Levy’ (CIL) will fall way short of expectations and other Government Funding will be in ‘shortfall’ to the tune of £ Billions (report produced by AECOM) who also produced the RDC “Sustainability Analysis”, please explain why they did not cite this issue.
Stakeholder Ref: CP15678E Community Representative Ref: 29007

HRA study of funding under section 106, particularly to fund the local Clinics (£164k recently) which was put to the NHS and RDC fell short of the required sum in view of the increased population. HRA requested consultation to allow co-ordinated conclusions. No surprise this was ignored by all concerned.
The normal LA practices are that a 10 year plan allowing the income to be divided into categories of funding allowing for contingencies for each element of Infrastructure to satisfy needs as they arise, so the question is what have you done with those budgets, as we keep being informed of shortage of funds, perhaps the auditors are allowed to explain how that money was spent. We ask, under ‘The Freedom of Information Act’ why the Hullbridge infrastructure was allowed to deteriorate over at least 50 years.
HRA object to the IDP and CIL because these should be RDC, ECC and Agency obligations to use the contingency funds and not produce more rules which allow the LA to cover up their own accountability inadequacies and should not be an ‘extra’ burden to the community.
If approved, this will set a precedent for other forms of funding from the communities. The community are concerned by this new statement lacking in the Core Strategy and the Land Development Framework. Can you blame the community for showing concern that LA mismanagement of funds fall to the communities having to make good the shortfall wherever they occur.

Page 9. Item 3.2. 36 Sites additional development Land.
The Land Mass measured and stated in this clause we find is out of date because several hectares have already been built on since 2012 which should have been taken into consideration, thus reducing the Land Mass area. Your review and consultation is necessary and we look forward to open discussions in
accordance with the Localism Act.

Section 3. Please refer to our Exhibit A- Development density comparison on pages 14/15.
The total measure of 36 sites = 124 hectares (approximately) which will provide a capacity of 3720 dwellings at minimum 30 dwellings per hectare. The minimum density of 30/60 dwellings per hectare can provide 3720 to 7440 dwellings.

Boundary Line.
Further examination of the same map A indicates that 30.5% of the land lies in the adjoining Rawreth Parish. Please refer to our Exhibits A and B on pages 14-15 and 16 – 20 consecutively.
The result provides the following information:
In our examination of the New Local Plan Document, we are unable to find any explanation for dealing with this ‘division’. Using our previous submission in relation to the Boundary Line indicated on the Ordnance Survey shown and confirmed by the Local Boundary Commission, our correspondence with Rochford District Council requesting clarification on the Parish Council division and the financial implications, they refused to accept the existence of this Boundary line. At a meeting with the developer, we were informed that RDC will allow Council Tax collected by Hullbridge on behalf of Rawreth Parish. Have RDC made the necessary application to LBC for the necessary changes to the Boundary Line and whether or not Rawreth will be amalgamated with Hullbridge at some future date.
The same principle applies with the Boundary Commission England and the National Planning Policy Framework regulations, again we ask for specific dialogue to satisfy the regulations. One of the Green Belt policy purpose is to prevent neighbouring towns/villages from merging into one, Can RDC explain why they seem to have abandoned this policy.

Page 10. Clauses 3.6 to 3.8, Figures 2 and 3. “Travel to work outflows and inflows”.
The travel patterns have changed since 2011 by about 18% with the increase of population. We request a review of the information being given, affecting transport congestion and lack of proper infrastructure.

Page 11. Clauses 3.9 to 3.12. Employment statistics.
We suggest a review is necessary. What guarantees will the prospective developers give to employ local skills.
Stakeholder Ref: CP15678E Community Representative Ref: 29007

Pages 12 and 13. Our Environment. Clause 3.13
Previous Statements made by the Environment Department, Highways & Water Agencies and the HSE suggesting assessments made in 2011 and 2014 were ‘insufficient’ and all future assessments will also fall short of efficiency with funding being used as an excuse to minimise costs giving rise to lack of obligations to this community and to blame Government pressure to satisfy the development quota being used as an excuse to limit the scale of assessments, thus breaching the clauses in the LDF, NPPF and Localism Act.
The same agencies gave evidence to the Planning Inspector that Hullbridge is a ‘sparsely populated’ area. This can be classified as a false statement knowing that Flood water has been a major concern for many years including surface and foul water discharges onto roads and gardens, due to lack of improved drainage facilities and gardens constantly under water. Further land being put forward for development will exacerbate the infrastructure issue. We are informed that RDC do not keep records of ‘Public health’ issues, any complaints are ignored. Foul sewers are grossly overloaded. A full upgrade of the drainage system has always been overdue. This issue should be investigated rigorously by the RDC and it is their responsibility to inform the ECC.

Page 14. Our Communities.
The Hullbridge population count for 2011 census states a population of 6858. HRA support from the community in 2017 suggests 7000 and in 2019 = 7400.
The current development of 500 homes proves an annual population increase from 2019 to 2023 = 9400 population. The growth in the previous 3 decades (census) indicated an average of 2.2% increase. This indicates an average annual increase of 2% per census. This is contrary to the Core Strategy, LDF and the NPPF and the Localism Act that any increase in population should follow the historical line. Hopes rise for a new climate of close Community Consultation.

Page 15 Table 1. Breakdown of 2011 Population Census.
These possible developments will increase the Hullbridge population (see Exhibit B- Population) to 35,900 which will be close to the present Rayleigh population within 15 to 20 years.

Hullbridge, presently with a ‘village status’ will become a Town with a population probably second only to Rayleigh. The Portfolio Holder (Councillor Ian Ward) stated that the Local Plans have changed and it was now paramount to ‘listen’ and closely ‘consult and engage’ with the community, but most people are sceptical that our voices will be heard, and the necessary amendments put forward by the HRA ‘professionals’ will not be heeded. Hullbridge presently consider all verbal utterances are not considered in favour of the community, and no changes are evident except for many of our issues on planning which HRA had to investigate without any RDC help to satisfy the community q & a meetings.

Clause 3.20 Using HRA figures given above we are unable to reconcile with your statement that “the proportion of residents in all demographic ranges will remain ‘stable’. We advise the RDC to review their information and observe the contents of our Exhibit A and B on pages 14/15 and 16-21 provides the necessary calculation, showing exceptional over-population.

Page 16
Clauses 3.21 to 3.25 needs to be reviewed in respect of the statements made being out of date, as the document is prepared using data prescribed in 2011 without fact-finding surveys being conducted to carry out ‘forward planning’ especially with the owner-occupation criteria becoming financially unreliable. With experience of the Public Finance Initiative (PFI) being suspect it will be necessary to return to Council House Building with participation between Local Government and Housing Associations being a prime ‘home provider’ but all motives are suspect.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

Section 4
Page 17 – Spatial Challenges.
Great emphasis is placed on the laws governing the National Planning Policy Framework. We highlight the following to allow you to respond to the Hullbridge Residents Association.
We request you uphold the clauses requiring Consultation with the community Representative such as the HRA with and allowing replies to issues of importance to the community, before finalising the New Local Plan.

Consultative Objections.
We submit our “Consultative Objections” and conform to the NPPF policy namely – that the Local Authority and the ‘Applicants’ must work closely with those directly affected by their proposals to evolve designs that take account of the views of the community.

Brownfield and Greenfield land.

The allocation DPD Document (Feb 2010)- Discussion & Consultative Document on page 1 states that the Council Statement of Community Involvement is committed to Regulations 25 Public Participation in the preparation of Planning for the District (revised 2017). We ask for the right to be properly consulted on this issue that the allocation document has no brownfield sites identified as given in our Exhibit B.

Section 5.
Page 24. Clause 5.1. Our Vision and Strategic Objectives.
HRA experience gained over 9 years of deliberations over the Hullbridge ‘developments’ and Local Plans, that this has not been a success as the majority of the 185 issues submitted in 2014, not being satisfied, and with alliances formed with other localities the same view is expressed. The fact that you did not respond indicates that we are right on all the issues submitted to you and hope the Planning Inspector will take this into account in respect of all future “Consultation”.
We hope that the Planning Inspector takes into account the atmosphere of distrust by the community.

Clause 5.4 Our current Vision
HRA disagree that what is being prescribed on the Hullbridge Plan will allow the community to have the best quality of life, when there is at least 20 years of disruption to look forward to, which will blight our lives. Whole sale development is taking place with major clauses in the NPPF being disregarded.
A “Considerate Contractor Scheme Notice must be a requirement for all contractors to observe the rules towards the community.

Page 26. Clause 5.10. Rochford District 2037. Our Society
We disagree with the statement made that’ the green infrastructure network across the district has been enhanced to support our population. Many hectares of Green Belt Land are being allowed to be developed disregarding all the clauses which are supposed to protect the Green Belt and Government directives. Articles written by the Campaign to Protect Rural England (CPRE) bear witness to the contrary and the community remain sceptical about the final outcome.
The community believe that the homes will be for the over- burgeoning populace of London, not of Essex. We fail to see how you can demonstrate the indigenous population expansion taking priority.

Page 28. Cl. 5.11. Strategic Objective 13. Flood.
Experience gained by the lack of proper assessments on flood, disregarding all the issues provided to you in 2013. Decisions are being made according to financial constraints.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

RDC now have a recipe for disaster in an area naturally susceptible to surface water discharge from the ‘Rayleigh Heights’ about 65m above ground level and surrounding areas of vulnerable Watery Lane.


Page 29. Strategic Priority 5. Climate change.
The Hullbridge community are concerned that the information provided by various Agencies and Insurance Companies that the 1:100 flood incident is flawed and is more likely to be a maximum 1:25 due to Climate change. There is scepticism that the LA will help change the law and this will be detrimental to the community at large. Sea levels have officially been recorded as rising some 150mm above sea level from the beginning of this century and are forecast to rise by 500mm before the end of this century.

Section 6.
Pages 32 to 38. Clauses 6.8 to 6.29. Tables 2 to 4.
Advance notice. Property Insurance.
The potential Property Insurance costs against ‘flood risk’ and ‘subsidence in these areas, can range from £2500 to £5000. per household depending on the risk analysis.
An exercise on Post Codes SS5 reveals that using the ‘Hawkeye’ system determining the level of associated risks such as flood, subsidence etc., the combined results show that in both instances, subsidence is Red, meaning these are perils which will either be excluded or a large excess applied in respect of subsidence – usually £2,500.00 (£1000.00 being ‘Standard’) and for any areas susceptible to flood, without protection barriers or flood defences will increase the Cost Risk to £5,000.00 per property making ‘flood excess’ a priority and no claims accepted by the Insurance Companies if this is applied to development in flood areas.

Page 38 to 40. Clauses 6.29 to 6.33. Homes for purchase and Affordable Homes.
This document was obviously written before the changes which have taken place in the financial industry and Government policies. The change in ‘affordability’ has not been fully considered. We advise you to review and amend this statement accordingly.
How can you demonstrate the ‘affordability’ during this financial climate, which are likely to continue for the next 10 years, irrespective of the incentives given on stamp duty and directives to the lending institutions? Most younger adults will have great difficulty to purchase homes and maintain mortgage payments.

Table 5 Rochford District- Settlement Hierarchy.
We have always had an issue with the infringement of the Green Belt. Most of the present developments recently completed or under construction are being built on Green Belt land disregarding brownfield sites. We suspect that the new Land Development Framework document questions the need to build on the green belt land. Our Exhibit B presents you with our statements on your LDF

Page 45. Clause 6.48. Housing Density Options .
Earlier we provided calculations for the lowest density of development per hectare, It is evident that the option may be for up to 60 homes per hectare which will increase the incentive provided by the Government and risk the long term harmony in the community and will cause even greater strain and stress on the Hullbridge infrastructure and the community.
RDC must take advantage of requesting funds from the Government announcement of £866m funds from the Housing Infrastructure Fund (HIF) to enable the existing Hullbridge infrastructure be brought up to standard, on the grounds that the previous planning regime’s over the last 30 years have been negligent in dealing with the existing infrastructure as suggested on page 6. Clause 1.21.



Stakeholder Ref: CP15678E Community Representative Ref: 29007


Section 8.
Local Highways Capacity and Infrastructure. Clause 8.3 LDF Development Management Submission Document- Section 5- Transport page 73. Improvements to local road network
The only access points to get to Hullbridge is Lower Road and Hullbridge Road. Watery lane should not be considered as a main thoroughfare and we despair that the Essex County Council, Rochford District Council and the Agencies seem to ignore this fact. We want the Planning Inspector to review his statement in the ‘Planning approval’ given in 2014 that RDC consult with HRA on the feasibility for improvement of this Lane, as it is not ‘fit for purpose’.

Highways Risk Analysis.
HRA are concerned that a proper Highways Risk Analysis has not been carried out by the Core Strategy, NPPF and LDF documents. Further consideration must be given for ‘transparency’ as stated in The Localism Act (2011). Recent replacement of 50 years old Gas services emphasises the disruption which
will be caused by both existing and future construction work. County and Local Authorities please take note.

Watery Lane, is in urgent need of improvement and HRA have corresponded with RDC, ECC and all the Agencies showing Watery Lane and Hullbridge Road are identified as traffic congestion points, in clauses 8.13 to 8.15.
We request that RDC/ECC/Agencies contact the SAT NAV services to remove Watery Lane as a general thoroughfare and emphasise this is “weight restricted” and ‘width restrictive’ and speed limits reviewed with adequate signage..
This lane is too narrow for any vehicles over 30 cwt. The lane is without a public footpath making this lane a health and safety issue which needs urgent rectification. HRA suggest that this section of the document should be reviewed, particularly as the Planning Inspector acknowledged HRA argument that Watery Lane is not ‘fit for purpose’, we reject the statement that Watery Lane is NOT part of the “Strategic Highways Network” please review, amend and highlight for the Planning Inspector to view..

Accessibility to Services. Hullbridge has many un-adopted, single lane and unmade roads making access difficult for the Fire, Police, Refuse, Ambulance and general delivery services and will not be suitable for constant construction site traffic for next 20 years a covenant should be inserted to allow the ECC and their Agencies to make urgent contingencies before the matter gets worse as expansion proceeds..

Fire Hydrants. Hullbridge only has 8 Fire Hydrants to serve the whole village, which is considered inadequate for the fire services.


Page 85 - 90. Clause 8.22 to 8.37. Sustainable Travel.
The transport system is being overhauled to reduce the number of buses serving the communities and the frequency, if this carries on, there will be future major problems. Please refer to LDF Allocations Submission Document Page 60 Cl 3.177/178.

Page 87. Clause 8.31 Rayleigh Air Quality.
Reading this clause we are not confident that something will be done to provide good quality air. It was reported in the media, that dangerous levels of nitrous oxide caused by diesel fumes are being recorded in and around the Rayleigh area. Air quality is lacking in both depth and detail which means the RDC ‘evidence base’ on the subject of traffic, is lacking. Please explain your remedy? This pollution has been apparent for many years but ignored. The community now demand action to remedy this issue.

Stakeholder Ref: CP15678E Community Representative Ref: 29007


Page 92 to 96. Clause 8.45 to 8.58. Water and Flood Risk management.
Flood
At times of flood (frequent - 25 times in 5 years), in Watery Lane, has resulted in many accidents, causing ‘gridlock’ to the whole local traffic system in Hullbridge and surrounding areas. Drainage is unable to cope with excess flood water resulting in overflow of excrement and water into roads and gardens and cross-surging foul water and surface water services

Page 96- 98. Clause 8.59 – 8.66. Renewable Energy Generation.
We agree about the ‘renewable energy’ ‘dream’ from all sources and accept there is natural course of events to be taken for the sake of the concerns on Global Environment. It is the political challenges which become the difficult part to address. Perhaps Political will may help.

Page 98-100. Clause 8.67- 8.75. Planning Obligations and Standard Charges.
Local Authorities ignore the observations and pleas made to review and observe the standards laid down by the NPPF, Core Strategy and LDDF to allow ‘proper’ consultation with the community representatives.
The NPPF guidelines on all planning obligations suggest that the 3 tests as set out, must pass:
1 Necessary to make the development acceptable in planning terms.
2 Directly related to the development.
3 Fairly and reasonable related in scale and kind to the development.
The community want an action plan to allow meaningful consultation with the community.

Section 9 Supporting Health, Community and Culture.
Page 101- 120. Clauses 9.1 – 9.61. Health Impact assessment- Cl 3.186
We (HRA) brought to the authorities’ attention various anomalies in the financial accountability in assessing the “Contributions” without giving considerations to contingency for increases in inflation and time related uplift. HRA are happy to be consulted in the future.
HRA investigated the Health Provision indicated in Section 106 ‘contributions and concentrated on the sum stated to be for the Riverside Medical Centre on Ferry Road and found the sum stated to be inadequate. We fear the same decisions may be made for the foreseeable future. As HRA have been active on this issue it would be in the interests of all parties to consult and agree a course of action.

Section 10 Protecting and Enhancing our Environment.
Page 121 - Clause 10.1 to 10.4
General planning policy of the NPPF suggests minimising vulnerability and provide resilience to climate change impacts. RDC and ECC must provide a course of actions.

Page 121 – 141. Clause 10.5 – 10.72 Green Belt
We agree the purposes of the NPPF clause 10.7-10.8 in that the 5 purposes of the Green Belt set out to:
1. Check the unrestricted sprawl of large built up areas
2. Prevent neighbouring towns merging into one another.
3. Assist in safeguarding the countryside from ‘encroachment.
4. Preserve the setting and special character of historic towns.
5. Assist in urban regeneration, by encouraging the recycling of derelict and other urban land ie Brownfield Sites. Inappropriate development. (Page 122. Clause 10.8) Specifically states that the construction of new buildings in the Green Belt is generally considered to be inappropriate development.
The Hullbridge Residents Association respectively request that Rochford District Council adhere to these policies and review the New Local Plan Document. It may be appropriate to classify this as “Special Measures” and allow the intervention of a Planning Inspector to adjudicate.

Stakeholder Ref: CP15678E Community Representative Ref: 29007

Section 11. Detailed Policy Considerations. Pages 142- 165
Page 142. Clause 11.2 Mix of Affordable Homes

In HRA discussions with a developer we were advised that the RDC stated that the Core Strategy and the Land Development Framework were ‘out of date’ therefore some clauses were not applicable.
The same situation applied to discussions when applied to the Localism Act. The Core Strategy and the NPPF are evident in many statements in this new Local Plan document, so, we consider there has been no change in the above main documents, action is necessary.

Page 155. Clause 11.45 Brownfield Sites. HRA have taken into account clauses 11.45/ 46 and taken into consideration that all Brownfield sites must have priority. NPPF paragraph 89 and Policy DM10 on brownfield development should be an over-riding factor when producing these documents. We refer you to the ‘ambitious’ clauses stipulated in the LDF Management Submission Document- Clause 3 page 33- The Green Belt and Countryside – Vision. Short term. The first paragraph stipulates the “openness and character” of the Rochford Green Belt continues to be protected. Constant reference by our MP Mark Francois has been ignored which places him in an awkward position.

Page 164. Contaminated land. Cl 11.77 to 11.81. Specific example of for
Nevendon Yard Breakers Yard, Lower Road, Hullbridge. Proposed 90 units.
This site is contaminated over a 70 year period and the costs of eradication will be high. The outline application plans are presently delayed for that reason while a historical document is being prepared.

LOCALISM ACT 2011 chapter 20. Item 2.1 (5th bullet point)
The ‘Localism Act’ was brought into force in 2011, the community did not have the opportunity to apply the clauses of this act. This act stipulates that the Local Community has: the ‘right to challenge’ (Part 5, Chapter 2, Clauses 81 to 86).


End of Appeal For Withdrawal.

Dear Sir,
Re: Stakeholder: Reference CP15678E. Community Representative No. 29007.

New Local Plan 2021 Consultation. Issues and Options Documents & Statement of Community Involvement and the Spatial Options documents.

We request Rochford District Council to invite the Government Planning Inspector to find that the New Local Plan 2021 must be withdrawn for reasons mentioned below.
In our consideration the Map A, on the basis of the relevant Legislation Guidance in the National Planning Policy Framework is not:
Positively Prepared
Justified
Effective
Consistent with National Policy

There are sufficient clauses in the NPPF, LDF and Localism Act which stipulate that all issues must be considered including Infrastructure and in areas environmentally threatened as shown in the Environment Agency and the Insurance Company data (Flood maps). It is imperative proper assessments be made in accordance with the NPPF regulations such as Flood, Road Network, Proximity to rivers and all issues set out below. Our experience from the current Malyons Lane large development that our SCI will be ignored again unless we have support from our MP Mark Francois and all the Councillors who are continually proud to state they are Community minded.

The Hullbridge Residents Association have viewed the Local Development Framework Evidence Base and note that the contents are a repeat of the documents issued in 2015 as are the documents mentioned above
Along with the accompanying Integrated Impact Assessment.

Section 1. Introduction
1.1 States this is a review document of the original adoption in 2016, now presented in repetition but revised in 2015 and 2017 (for 2021).

We understand the need for additional homes, but we are concerned that ‘Infrastructure is not given priority as stated by our MP Mark Francois and indeed Government directives, particularly the existing infrastructure but continually being ignored.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

Page 1. Clause 1.2

HRA produced and delivered to RDC a 45-page document on the Core Strategy, Land Development Framework (LDF), National Planning Policy Framework (NPPF) and Localism Act for a development in progress and submitted some 525 issues in the planning documents presented by RDC without a proper response.
The clauses about Community Consultation being important is just a paper exercise to convince the Planning Inspector that the community support all the data produced.

HRA 9 years of experience has shown RDC and Councillors lack of the understanding or interpretation of Community Involvement, proper consultation and transparency, and fear another regretful experience with all sites being put forward for possible development. Having spoken to some Councillors they state that these site will not necessarily be approved to allow planning applications, but past experience does not provide any confidence that the community issues will be taken into account..
We make a plea to the Government Planning Inspector to investigate reasons why the community are ignored in proper consultation.

36 Sites.
We demonstrate our reasons for our rejection of many sites (stated in our document marked “Exhibit B- Issues and Options”) until the subject of the infrastructure (in all aspects- including existing) are reviewed This is an important subject and we extend our Plea to the Planning Inspector to set this review in motion and allow full participation by the Community Representative.

We consider the following clauses of the NPPF and Core Strategy must be applied:

NPFF 3– Core Planning Principles. Pages 1, 5-6, Clauses 1-2, 6-17.
NPPF 4 – Promoting Sustainable Transport.
NPPF 5 – Supporting high quality communications infrastructure. With roads/transport a priority.
NPPF 6 – Delivering a wide choice of high quality homes.
NPPF 7- Requiring Good Design.
NPPF 8 – Promoting Healthy communities.
NPPF 9 - Protecting the Green Belt land.
NPPF 10- Meeting the Challenge of Climate Change, Flooding & Coastal change.
NPPF 11- Conserving and enhancing the future environment.
NPPF Plan Making – Local Plans (p. 37).
NPPF Using a Proportionate evidence base- (p. 38).
NPPF Ensuring Viability and Deliverability- ( p. 41).
NPPF Decision taking – Pre-application engagement & front loading, (p. 45).
Technical Guidance to the NPPF- Flood risk on page 2. Sequential and Exceptional Tests p. 3 to 7.
NPPF - Sequential and Exceptional Tests –

Drainage
Sustainable drainage systems;
We have submitted documents in respect of the existing drainage system needing substantial improvements prior to any links being provided to the new developments and should be part of the necessary required Infrastructure works we have continually highlighted that the present system is not ‘fit for purpose’, but this was ignored. RDC are duty bound to inform ECC (RDC state that this is not their responsibility.


Stakeholder Ref: CP15678E Community Representative Ref: 29007


Page 2.
Clause 1.7 Statement of Community Involvement.
Having been disappointed with the first Statement of Community Involvement document in 2013 and 2016 we take the clause 1.7 on page 2 seriously and look forward to proper ‘consultation’ by RDC, and not use our submission purely as a ‘tick-box’ exercise to prove to the Planning Inspector that the regulations are observed and, our views have been taken into account but we have not seen these issues progressed to amendments in the Local Plan. HRA represent the Hullbridge community and have the right for engagement as stated in the NPPF and the Localism Act.

Clauses 1.8 & 1.9.
A plan indicating 36 additional sites on Map A in Hullbridge along with a further 6 sites not identified on Map A. Please refer to our Exhibit A on pages 14 and 15.

Clause 1.10 is of special interest as it mentions “on-going consultation” at every stage. We did not have the opportunity to discuss ‘The Draft Scoping Report’ which was published on the RDC websites, and the residents, businesses and other ‘stakeholders’ on the RDC mailing list were not consulted (HRA is a Stakeholder and Representative)- continually ignored by RDC- indeed HRA have correspondence relating to this issue that “if we did not like it we should consider litigation’.

Clause 1.14 on page 4 is of special interest to us as we placed emphasis on the Localism Act (2011) with the Managing Director of RDC and were told that the Localism Act was irrelevant. Why is it now more relevant than before? We request this ‘Act’ to be included as it supports Human Rights.

Clause 1.16. Only one ‘drop-in session’ was set up at Hullbridge Community Centre on 24/8/21. The attendance was low, HRA committee had 9 committee members present who asked questions and had responses which do not reflect the issues put forward in this ‘Plea’. One answer took us by surprise, that the Essex Design Guide which we have referred to throughout has been replaced by Rochford own Design Guide. When we consider the reduced staff levels with some unqualified planning staff it leads us to believe that this design guide will be subject to much criticism. We hope the Government Inspector will take this into account.

Planning law requires that “Call for Sites” which falls part of the development plan in accordance with the Regulations Governing Neighbourhood Planning Laws- NPPF 6 - Plans and Strategies – Part 6, Chapter 1, clauses 109 to 113, allows for Neighbourhood Planning – Part 6, chapter 3, clauses 116 to 121., and gives the community the right to Consultation – Part 6, chapter 4, clause 122. We challenge RDC to approve our application for this Neighbourhood Planning Group and a Statutory Consultee status which will also be an asset to the Hullbridge Parish Council. No explanation is given for reasons why we are not allowed to have consultation to give us good reasons why the regulations are not being properly debated and a conclusion found. This attitude denies community skills and professions adequately proven over 9 years of hard work, not acknowledged.

The four principles that follow imply that the core strategy should be relevant, sustainable and ‘Fit for Purpose’ and become part of the NPPF and LDF:
• Positively prepared.
Our observation on the previous Local Plan that insufficient forward planning had been carried in accordance with the Core Strategy which should have been adhered to and we will not be surprised if the same ‘policy’ will prevail. We look forward to the Planning Inspector requesting a coordinated approach and consultation with the community representatives, as the present system is not fit for purpose.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

• Justified.
In view of the aforesaid we do not believe there was any justification to allow more sites to be put forward without clear thinking on assessments being made in respect of the “existing Infrastructure”, and the use of Green Belt land being used instead of Brownfield land and the other issues stated in this document.
The Core Strategy, NPPF and LDF and Localism Act all express that Green Belt land should only be used as a last resort and only under exceptional circumstances, many issues which we have demonstrated have not been addressed sufficiently. Can RDC demonstrate why they are unable to adhere to the rules and regulations designed to safeguard the community.
According to the Localism Act 2011, we have demonstrated that transparency and consultation were lacking with the community. This has to be rectified and included within the proposed Local Plan.
• Effective
The conditions for the development of the 36 Hullbridge sites will not be satisfied for the reasons given above, therefore we consider a complete review of these possible proposed developments and the Core Strategy allows for the community to raise these issues and get into meaningful dialogue with RDC.
• Consistent with National Policy
National policy insists that all the policies stated should be transparent, proper consultation pursued in relations to all the development criteria. We do not believe that proper feasibility studies, risk analysis have been conducted in order to satisfy the requirements of the NPPF and LDF. Most subjects referred to in this presentation will imply reasons for withdrawal, in view of Government directives and regulations listed above.
The Localism Act 2011 Chapter 20. suggested meaningful dialogue with the HRA. Our residents asked what guarantees will be given to HRA that we will be listened to, not merely placing this document on RDC website to satisfy the Planning Inspector requirements. We require RDC Planning/Legal department to clarify.

Clauses 1.18 and 1.19 speaks of ‘community-led planning’ which is of interest to HRA but all our applications and requests for clarification are ignored. We have consistently placed great emphasis on ‘community cohesion’. Which makes for good public awareness. We can produce correspondence to the Parish Council for cohesion in respect to the whole community and help to remove the divisions which exist at present.
HRA have requested support from the Hullbridge Parish Council and indeed our rights should be upheld in accordance with the Localism Act..

Page 5.
Clauses 1.20 and 1.21
How can the RDC ensure that our proposals can be supported for the benefit of the community.
Clause 1.21 Infrastructure Delivery Plan (IDP) and the Community Infrastructure Levy (CIL) will be prepared to set out the circumstances that the CIL will be applied and the key infrastructure that the CIL will seek to fund. The Council will seek to fund this through a ‘Community levy’. This implies that the RDC are not protecting the community. ECC financial planning administration needs reviewing on the subject of ‘contingencies’ which should apply to all categories of infrastructure and other important categories to allow for future planning, maintenance and improvement.

The Essex County Council document “Greater Essex Growth” states that Greater Essex Growth and Infrastructure Framework 2016 is not listed or discussed. The Executive Summary says that Section 106 and ‘Community Infrastructure Levy’ (CIL) will fall way short of expectations and other Government Funding will be in ‘shortfall’ to the tune of £ Billions (report produced by AECOM) who also produced the RDC “Sustainability Analysis”, please explain why they did not cite this issue.
Stakeholder Ref: CP15678E Community Representative Ref: 29007

HRA study of funding under section 106, particularly to fund the local Clinics (£164k recently) which was put to the NHS and RDC fell short of the required sum in view of the increased population. HRA requested consultation to allow co-ordinated conclusions. No surprise this was ignored by all concerned.
The normal LA practices are that a 10 year plan allowing the income to be divided into categories of funding allowing for contingencies for each element of Infrastructure to satisfy needs as they arise, so the question is what have you done with those budgets, as we keep being informed of shortage of funds, perhaps the auditors are allowed to explain how that money was spent. We ask, under ‘The Freedom of Information Act’ why the Hullbridge infrastructure was allowed to deteriorate over at least 50 years.
HRA object to the IDP and CIL because these should be RDC, ECC and Agency obligations to use the contingency funds and not produce more rules which allow the LA to cover up their own accountability inadequacies and should not be an ‘extra’ burden to the community.
If approved, this will set a precedent for other forms of funding from the communities. The community are concerned by this new statement lacking in the Core Strategy and the Land Development Framework. Can you blame the community for showing concern that LA mismanagement of funds fall to the communities having to make good the shortfall wherever they occur.

Page 9. Item 3.2. 36 Sites additional development Land.
The Land Mass measured and stated in this clause we find is out of date because several hectares have already been built on since 2012 which should have been taken into consideration, thus reducing the Land Mass area. Your review and consultation is necessary and we look forward to open discussions in
accordance with the Localism Act.

Section 3. Please refer to our Exhibit A- Development density comparison on pages 14/15.
The total measure of 36 sites = 124 hectares (approximately) which will provide a capacity of 3720 dwellings at minimum 30 dwellings per hectare. The minimum density of 30/60 dwellings per hectare can provide 3720 to 7440 dwellings.

Boundary Line.
Further examination of the same map A indicates that 30.5% of the land lies in the adjoining Rawreth Parish. Please refer to our Exhibits A and B on pages 14-15 and 16 – 20 consecutively.
The result provides the following information:
In our examination of the New Local Plan Document, we are unable to find any explanation for dealing with this ‘division’. Using our previous submission in relation to the Boundary Line indicated on the Ordnance Survey shown and confirmed by the Local Boundary Commission, our correspondence with Rochford District Council requesting clarification on the Parish Council division and the financial implications, they refused to accept the existence of this Boundary line. At a meeting with the developer, we were informed that RDC will allow Council Tax collected by Hullbridge on behalf of Rawreth Parish. Have RDC made the necessary application to LBC for the necessary changes to the Boundary Line and whether or not Rawreth will be amalgamated with Hullbridge at some future date.
The same principle applies with the Boundary Commission England and the National Planning Policy Framework regulations, again we ask for specific dialogue to satisfy the regulations. One of the Green Belt policy purpose is to prevent neighbouring towns/villages from merging into one, Can RDC explain why they seem to have abandoned this policy.

Page 10. Clauses 3.6 to 3.8, Figures 2 and 3. “Travel to work outflows and inflows”.
The travel patterns have changed since 2011 by about 18% with the increase of population. We request a review of the information being given, affecting transport congestion and lack of proper infrastructure.

Page 11. Clauses 3.9 to 3.12. Employment statistics.
We suggest a review is necessary. What guarantees will the prospective developers give to employ local skills.
Stakeholder Ref: CP15678E Community Representative Ref: 29007

Pages 12 and 13. Our Environment. Clause 3.13
Previous Statements made by the Environment Department, Highways & Water Agencies and the HSE suggesting assessments made in 2011 and 2014 were ‘insufficient’ and all future assessments will also fall short of efficiency with funding being used as an excuse to minimise costs giving rise to lack of obligations to this community and to blame Government pressure to satisfy the development quota being used as an excuse to limit the scale of assessments, thus breaching the clauses in the LDF, NPPF and Localism Act.
The same agencies gave evidence to the Planning Inspector that Hullbridge is a ‘sparsely populated’ area. This can be classified as a false statement knowing that Flood water has been a major concern for many years including surface and foul water discharges onto roads and gardens, due to lack of improved drainage facilities and gardens constantly under water. Further land being put forward for development will exacerbate the infrastructure issue. We are informed that RDC do not keep records of ‘Public health’ issues, any complaints are ignored. Foul sewers are grossly overloaded. A full upgrade of the drainage system has always been overdue. This issue should be investigated rigorously by the RDC and it is their responsibility to inform the ECC.

Page 14. Our Communities.
The Hullbridge population count for 2011 census states a population of 6858. HRA support from the community in 2017 suggests 7000 and in 2019 = 7400.
The current development of 500 homes proves an annual population increase from 2019 to 2023 = 9400 population. The growth in the previous 3 decades (census) indicated an average of 2.2% increase. This indicates an average annual increase of 2% per census. This is contrary to the Core Strategy, LDF and the NPPF and the Localism Act that any increase in population should follow the historical line. Hopes rise for a new climate of close Community Consultation.

Page 15 Table 1. Breakdown of 2011 Population Census.
These possible developments will increase the Hullbridge population (see Exhibit B- Population) to 35,900 which will be close to the present Rayleigh population within 15 to 20 years.

Hullbridge, presently with a ‘village status’ will become a Town with a population probably second only to Rayleigh. The Portfolio Holder (Councillor Ian Ward) stated that the Local Plans have changed and it was now paramount to ‘listen’ and closely ‘consult and engage’ with the community, but most people are sceptical that our voices will be heard, and the necessary amendments put forward by the HRA ‘professionals’ will not be heeded. Hullbridge presently consider all verbal utterances are not considered in favour of the community, and no changes are evident except for many of our issues on planning which HRA had to investigate without any RDC help to satisfy the community q & a meetings.

Clause 3.20 Using HRA figures given above we are unable to reconcile with your statement that “the proportion of residents in all demographic ranges will remain ‘stable’. We advise the RDC to review their information and observe the contents of our Exhibit A and B on pages 14/15 and 16-21 provides the necessary calculation, showing exceptional over-population.

Page 16
Clauses 3.21 to 3.25 needs to be reviewed in respect of the statements made being out of date, as the document is prepared using data prescribed in 2011 without fact-finding surveys being conducted to carry out ‘forward planning’ especially with the owner-occupation criteria becoming financially unreliable. With experience of the Public Finance Initiative (PFI) being suspect it will be necessary to return to Council House Building with participation between Local Government and Housing Associations being a prime ‘home provider’ but all motives are suspect.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

Section 4
Page 17 – Spatial Challenges.
Great emphasis is placed on the laws governing the National Planning Policy Framework. We highlight the following to allow you to respond to the Hullbridge Residents Association.
We request you uphold the clauses requiring Consultation with the community Representative such as the HRA with and allowing replies to issues of importance to the community, before finalising the New Local Plan.

Consultative Objections.
We submit our “Consultative Objections” and conform to the NPPF policy namely – that the Local Authority and the ‘Applicants’ must work closely with those directly affected by their proposals to evolve designs that take account of the views of the community.

Brownfield and Greenfield land.

The allocation DPD Document (Feb 2010)- Discussion & Consultative Document on page 1 states that the Council Statement of Community Involvement is committed to Regulations 25 Public Participation in the preparation of Planning for the District (revised 2017). We ask for the right to be properly consulted on this issue that the allocation document has no brownfield sites identified as given in our Exhibit B.

Section 5.
Page 24. Clause 5.1. Our Vision and Strategic Objectives.
HRA experience gained over 9 years of deliberations over the Hullbridge ‘developments’ and Local Plans, that this has not been a success as the majority of the 185 issues submitted in 2014, not being satisfied, and with alliances formed with other localities the same view is expressed. The fact that you did not respond indicates that we are right on all the issues submitted to you and hope the Planning Inspector will take this into account in respect of all future “Consultation”.
We hope that the Planning Inspector takes into account the atmosphere of distrust by the community.

Clause 5.4 Our current Vision
HRA disagree that what is being prescribed on the Hullbridge Plan will allow the community to have the best quality of life, when there is at least 20 years of disruption to look forward to, which will blight our lives. Whole sale development is taking place with major clauses in the NPPF being disregarded.
A “Considerate Contractor Scheme Notice must be a requirement for all contractors to observe the rules towards the community.

Page 26. Clause 5.10. Rochford District 2037. Our Society
We disagree with the statement made that’ the green infrastructure network across the district has been enhanced to support our population. Many hectares of Green Belt Land are being allowed to be developed disregarding all the clauses which are supposed to protect the Green Belt and Government directives. Articles written by the Campaign to Protect Rural England (CPRE) bear witness to the contrary and the community remain sceptical about the final outcome.
The community believe that the homes will be for the over- burgeoning populace of London, not of Essex. We fail to see how you can demonstrate the indigenous population expansion taking priority.

Page 28. Cl. 5.11. Strategic Objective 13. Flood.
Experience gained by the lack of proper assessments on flood, disregarding all the issues provided to you in 2013. Decisions are being made according to financial constraints.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

RDC now have a recipe for disaster in an area naturally susceptible to surface water discharge from the ‘Rayleigh Heights’ about 65m above ground level and surrounding areas of vulnerable Watery Lane.


Page 29. Strategic Priority 5. Climate change.
The Hullbridge community are concerned that the information provided by various Agencies and Insurance Companies that the 1:100 flood incident is flawed and is more likely to be a maximum 1:25 due to Climate change. There is scepticism that the LA will help change the law and this will be detrimental to the community at large. Sea levels have officially been recorded as rising some 150mm above sea level from the beginning of this century and are forecast to rise by 500mm before the end of this century.

Section 6.
Pages 32 to 38. Clauses 6.8 to 6.29. Tables 2 to 4.
Advance notice. Property Insurance.
The potential Property Insurance costs against ‘flood risk’ and ‘subsidence in these areas, can range from £2500 to £5000. per household depending on the risk analysis.
An exercise on Post Codes SS5 reveals that using the ‘Hawkeye’ system determining the level of associated risks such as flood, subsidence etc., the combined results show that in both instances, subsidence is Red, meaning these are perils which will either be excluded or a large excess applied in respect of subsidence – usually £2,500.00 (£1000.00 being ‘Standard’) and for any areas susceptible to flood, without protection barriers or flood defences will increase the Cost Risk to £5,000.00 per property making ‘flood excess’ a priority and no claims accepted by the Insurance Companies if this is applied to development in flood areas.

Page 38 to 40. Clauses 6.29 to 6.33. Homes for purchase and Affordable Homes.
This document was obviously written before the changes which have taken place in the financial industry and Government policies. The change in ‘affordability’ has not been fully considered. We advise you to review and amend this statement accordingly.
How can you demonstrate the ‘affordability’ during this financial climate, which are likely to continue for the next 10 years, irrespective of the incentives given on stamp duty and directives to the lending institutions? Most younger adults will have great difficulty to purchase homes and maintain mortgage payments.

Table 5 Rochford District- Settlement Hierarchy.
We have always had an issue with the infringement of the Green Belt. Most of the present developments recently completed or under construction are being built on Green Belt land disregarding brownfield sites. We suspect that the new Land Development Framework document questions the need to build on the green belt land. Our Exhibit B presents you with our statements on your LDF

Page 45. Clause 6.48. Housing Density Options .
Earlier we provided calculations for the lowest density of development per hectare, It is evident that the option may be for up to 60 homes per hectare which will increase the incentive provided by the Government and risk the long term harmony in the community and will cause even greater strain and stress on the Hullbridge infrastructure and the community.
RDC must take advantage of requesting funds from the Government announcement of £866m funds from the Housing Infrastructure Fund (HIF) to enable the existing Hullbridge infrastructure be brought up to standard, on the grounds that the previous planning regime’s over the last 30 years have been negligent in dealing with the existing infrastructure as suggested on page 6. Clause 1.21.



Stakeholder Ref: CP15678E Community Representative Ref: 29007


Section 8.
Local Highways Capacity and Infrastructure. Clause 8.3 LDF Development Management Submission Document- Section 5- Transport page 73. Improvements to local road network
The only access points to get to Hullbridge is Lower Road and Hullbridge Road. Watery lane should not be considered as a main thoroughfare and we despair that the Essex County Council, Rochford District Council and the Agencies seem to ignore this fact. We want the Planning Inspector to review his statement in the ‘Planning approval’ given in 2014 that RDC consult with HRA on the feasibility for improvement of this Lane, as it is not ‘fit for purpose’.

Highways Risk Analysis.
HRA are concerned that a proper Highways Risk Analysis has not been carried out by the Core Strategy, NPPF and LDF documents. Further consideration must be given for ‘transparency’ as stated in The Localism Act (2011). Recent replacement of 50 years old Gas services emphasises the disruption which
will be caused by both existing and future construction work. County and Local Authorities please take note.

Watery Lane, is in urgent need of improvement and HRA have corresponded with RDC, ECC and all the Agencies showing Watery Lane and Hullbridge Road are identified as traffic congestion points, in clauses 8.13 to 8.15.
We request that RDC/ECC/Agencies contact the SAT NAV services to remove Watery Lane as a general thoroughfare and emphasise this is “weight restricted” and ‘width restrictive’ and speed limits reviewed with adequate signage..
This lane is too narrow for any vehicles over 30 cwt. The lane is without a public footpath making this lane a health and safety issue which needs urgent rectification. HRA suggest that this section of the document should be reviewed, particularly as the Planning Inspector acknowledged HRA argument that Watery Lane is not ‘fit for purpose’, we reject the statement that Watery Lane is NOT part of the “Strategic Highways Network” please review, amend and highlight for the Planning Inspector to view..

Accessibility to Services. Hullbridge has many un-adopted, single lane and unmade roads making access difficult for the Fire, Police, Refuse, Ambulance and general delivery services and will not be suitable for constant construction site traffic for next 20 years a covenant should be inserted to allow the ECC and their Agencies to make urgent contingencies before the matter gets worse as expansion proceeds..

Fire Hydrants. Hullbridge only has 8 Fire Hydrants to serve the whole village, which is considered inadequate for the fire services.


Page 85 - 90. Clause 8.22 to 8.37. Sustainable Travel.
The transport system is being overhauled to reduce the number of buses serving the communities and the frequency, if this carries on, there will be future major problems. Please refer to LDF Allocations Submission Document Page 60 Cl 3.177/178.

Page 87. Clause 8.31 Rayleigh Air Quality.
Reading this clause we are not confident that something will be done to provide good quality air. It was reported in the media, that dangerous levels of nitrous oxide caused by diesel fumes are being recorded in and around the Rayleigh area. Air quality is lacking in both depth and detail which means the RDC ‘evidence base’ on the subject of traffic, is lacking. Please explain your remedy? This pollution has been apparent for many years but ignored. The community now demand action to remedy this issue.

Stakeholder Ref: CP15678E Community Representative Ref: 29007


Page 92 to 96. Clause 8.45 to 8.58. Water and Flood Risk management.
Flood
At times of flood (frequent - 25 times in 5 years), in Watery Lane, has resulted in many accidents, causing ‘gridlock’ to the whole local traffic system in Hullbridge and surrounding areas. Drainage is unable to cope with excess flood water resulting in overflow of excrement and water into roads and gardens and cross-surging foul water and surface water services

Page 96- 98. Clause 8.59 – 8.66. Renewable Energy Generation.
We agree about the ‘renewable energy’ ‘dream’ from all sources and accept there is natural course of events to be taken for the sake of the concerns on Global Environment. It is the political challenges which become the difficult part to address. Perhaps Political will may help.

Page 98-100. Clause 8.67- 8.75. Planning Obligations and Standard Charges.
Local Authorities ignore the observations and pleas made to review and observe the standards laid down by the NPPF, Core Strategy and LDDF to allow ‘proper’ consultation with the community representatives.
The NPPF guidelines on all planning obligations suggest that the 3 tests as set out, must pass:
1 Necessary to make the development acceptable in planning terms.
2 Directly related to the development.
3 Fairly and reasonable related in scale and kind to the development.
The community want an action plan to allow meaningful consultation with the community.

Section 9 Supporting Health, Community and Culture.
Page 101- 120. Clauses 9.1 – 9.61. Health Impact assessment- Cl 3.186
We (HRA) brought to the authorities’ attention various anomalies in the financial accountability in assessing the “Contributions” without giving considerations to contingency for increases in inflation and time related uplift. HRA are happy to be consulted in the future.
HRA investigated the Health Provision indicated in Section 106 ‘contributions and concentrated on the sum stated to be for the Riverside Medical Centre on Ferry Road and found the sum stated to be inadequate. We fear the same decisions may be made for the foreseeable future. As HRA have been active on this issue it would be in the interests of all parties to consult and agree a course of action.

Section 10 Protecting and Enhancing our Environment.
Page 121 - Clause 10.1 to 10.4
General planning policy of the NPPF suggests minimising vulnerability and provide resilience to climate change impacts. RDC and ECC must provide a course of actions.

Page 121 – 141. Clause 10.5 – 10.72 Green Belt
We agree the purposes of the NPPF clause 10.7-10.8 in that the 5 purposes of the Green Belt set out to:
1. Check the unrestricted sprawl of large built up areas
2. Prevent neighbouring towns merging into one another.
3. Assist in safeguarding the countryside from ‘encroachment.
4. Preserve the setting and special character of historic towns.
5. Assist in urban regeneration, by encouraging the recycling of derelict and other urban land ie Brownfield Sites. Inappropriate development. (Page 122. Clause 10.8) Specifically states that the construction of new buildings in the Green Belt is generally considered to be inappropriate development.
The Hullbridge Residents Association respectively request that Rochford District Council adhere to these policies and review the New Local Plan Document. It may be appropriate to classify this as “Special Measures” and allow the intervention of a Planning Inspector to adjudicate.

Stakeholder Ref: CP15678E Community Representative Ref: 29007

Section 11. Detailed Policy Considerations. Pages 142- 165
Page 142. Clause 11.2 Mix of Affordable Homes

In HRA discussions with a developer we were advised that the RDC stated that the Core Strategy and the Land Development Framework were ‘out of date’ therefore some clauses were not applicable.
The same situation applied to discussions when applied to the Localism Act. The Core Strategy and the NPPF are evident in many statements in this new Local Plan document, so, we consider there has been no change in the above main documents, action is necessary.

Page 155. Clause 11.45 Brownfield Sites. HRA have taken into account clauses 11.45/ 46 and taken into consideration that all Brownfield sites must have priority. NPPF paragraph 89 and Policy DM10 on brownfield development should be an over-riding factor when producing these documents. We refer you to the ‘ambitious’ clauses stipulated in the LDF Management Submission Document- Clause 3 page 33- The Green Belt and Countryside – Vision. Short term. The first paragraph stipulates the “openness and character” of the Rochford Green Belt continues to be protected. Constant reference by our MP Mark Francois has been ignored which places him in an awkward position.

Page 164. Contaminated land. Cl 11.77 to 11.81. Specific example of for
Nevendon Yard Breakers Yard, Lower Road, Hullbridge. Proposed 90 units.
This site is contaminated over a 70 year period and the costs of eradication will be high. The outline application plans are presently delayed for that reason while a historical document is being prepared.

LOCALISM ACT 2011 chapter 20. Item 2.1 (5th bullet point)
The ‘Localism Act’ was brought into force in 2011, the community did not have the opportunity to apply the clauses of this act. This act stipulates that the Local Community has: the ‘right to challenge’ (Part 5, Chapter 2, Clauses 81 to 86).


End of Appeal For Withdrawal.

Dear Sir,
Re: Stakeholder: Reference CP15678E. Community Representative No. 29007.

New Local Plan 2021 Consultation. Issues and Options Documents & Statement of Community Involvement and the Spatial Options documents.

We request Rochford District Council to invite the Government Planning Inspector to find that the New Local Plan 2021 must be withdrawn for reasons mentioned below.
In our consideration the Map A, on the basis of the relevant Legislation Guidance in the National Planning Policy Framework is not:
Positively Prepared
Justified
Effective
Consistent with National Policy

There are sufficient clauses in the NPPF, LDF and Localism Act which stipulate that all issues must be considered including Infrastructure and in areas environmentally threatened as shown in the Environment Agency and the Insurance Company data (Flood maps). It is imperative proper assessments be made in accordance with the NPPF regulations such as Flood, Road Network, Proximity to rivers and all issues set out below. Our experience from the current Malyons Lane large development that our SCI will be ignored again unless we have support from our MP Mark Francois and all the Councillors who are continually proud to state they are Community minded.

The Hullbridge Residents Association have viewed the Local Development Framework Evidence Base and note that the contents are a repeat of the documents issued in 2015 as are the documents mentioned above
Along with the accompanying Integrated Impact Assessment.

Section 1. Introduction
1.1 States this is a review document of the original adoption in 2016, now presented in repetition but revised in 2015 and 2017 (for 2021).

We understand the need for additional homes, but we are concerned that ‘Infrastructure is not given priority as stated by our MP Mark Francois and indeed Government directives, particularly the existing infrastructure but continually being ignored.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

Page 1. Clause 1.2

HRA produced and delivered to RDC a 45-page document on the Core Strategy, Land Development Framework (LDF), National Planning Policy Framework (NPPF) and Localism Act for a development in progress and submitted some 525 issues in the planning documents presented by RDC without a proper response.
The clauses about Community Consultation being important is just a paper exercise to convince the Planning Inspector that the community support all the data produced.

HRA 9 years of experience has shown RDC and Councillors lack of the understanding or interpretation of Community Involvement, proper consultation and transparency, and fear another regretful experience with all sites being put forward for possible development. Having spoken to some Councillors they state that these site will not necessarily be approved to allow planning applications, but past experience does not provide any confidence that the community issues will be taken into account..
We make a plea to the Government Planning Inspector to investigate reasons why the community are ignored in proper consultation.

36 Sites.
We demonstrate our reasons for our rejection of many sites (stated in our document marked “Exhibit B- Issues and Options”) until the subject of the infrastructure (in all aspects- including existing) are reviewed This is an important subject and we extend our Plea to the Planning Inspector to set this review in motion and allow full participation by the Community Representative.

We consider the following clauses of the NPPF and Core Strategy must be applied:

NPFF 3– Core Planning Principles. Pages 1, 5-6, Clauses 1-2, 6-17.
NPPF 4 – Promoting Sustainable Transport.
NPPF 5 – Supporting high quality communications infrastructure. With roads/transport a priority.
NPPF 6 – Delivering a wide choice of high quality homes.
NPPF 7- Requiring Good Design.
NPPF 8 – Promoting Healthy communities.
NPPF 9 - Protecting the Green Belt land.
NPPF 10- Meeting the Challenge of Climate Change, Flooding & Coastal change.
NPPF 11- Conserving and enhancing the future environment.
NPPF Plan Making – Local Plans (p. 37).
NPPF Using a Proportionate evidence base- (p. 38).
NPPF Ensuring Viability and Deliverability- ( p. 41).
NPPF Decision taking – Pre-application engagement & front loading, (p. 45).
Technical Guidance to the NPPF- Flood risk on page 2. Sequential and Exceptional Tests p. 3 to 7.
NPPF - Sequential and Exceptional Tests –

Drainage
Sustainable drainage systems;
We have submitted documents in respect of the existing drainage system needing substantial improvements prior to any links being provided to the new developments and should be part of the necessary required Infrastructure works we have continually highlighted that the present system is not ‘fit for purpose’, but this was ignored. RDC are duty bound to inform ECC (RDC state that this is not their responsibility.


Stakeholder Ref: CP15678E Community Representative Ref: 29007


Page 2.
Clause 1.7 Statement of Community Involvement.
Having been disappointed with the first Statement of Community Involvement document in 2013 and 2016 we take the clause 1.7 on page 2 seriously and look forward to proper ‘consultation’ by RDC, and not use our submission purely as a ‘tick-box’ exercise to prove to the Planning Inspector that the regulations are observed and, our views have been taken into account but we have not seen these issues progressed to amendments in the Local Plan. HRA represent the Hullbridge community and have the right for engagement as stated in the NPPF and the Localism Act.

Clauses 1.8 & 1.9.
A plan indicating 36 additional sites on Map A in Hullbridge along with a further 6 sites not identified on Map A. Please refer to our Exhibit A on pages 14 and 15.

Clause 1.10 is of special interest as it mentions “on-going consultation” at every stage. We did not have the opportunity to discuss ‘The Draft Scoping Report’ which was published on the RDC websites, and the residents, businesses and other ‘stakeholders’ on the RDC mailing list were not consulted (HRA is a Stakeholder and Representative)- continually ignored by RDC- indeed HRA have correspondence relating to this issue that “if we did not like it we should consider litigation’.

Clause 1.14 on page 4 is of special interest to us as we placed emphasis on the Localism Act (2011) with the Managing Director of RDC and were told that the Localism Act was irrelevant. Why is it now more relevant than before? We request this ‘Act’ to be included as it supports Human Rights.

Clause 1.16. Only one ‘drop-in session’ was set up at Hullbridge Community Centre on 24/8/21. The attendance was low, HRA committee had 9 committee members present who asked questions and had responses which do not reflect the issues put forward in this ‘Plea’. One answer took us by surprise, that the Essex Design Guide which we have referred to throughout has been replaced by Rochford own Design Guide. When we consider the reduced staff levels with some unqualified planning staff it leads us to believe that this design guide will be subject to much criticism. We hope the Government Inspector will take this into account.

Planning law requires that “Call for Sites” which falls part of the development plan in accordance with the Regulations Governing Neighbourhood Planning Laws- NPPF 6 - Plans and Strategies – Part 6, Chapter 1, clauses 109 to 113, allows for Neighbourhood Planning – Part 6, chapter 3, clauses 116 to 121., and gives the community the right to Consultation – Part 6, chapter 4, clause 122. We challenge RDC to approve our application for this Neighbourhood Planning Group and a Statutory Consultee status which will also be an asset to the Hullbridge Parish Council. No explanation is given for reasons why we are not allowed to have consultation to give us good reasons why the regulations are not being properly debated and a conclusion found. This attitude denies community skills and professions adequately proven over 9 years of hard work, not acknowledged.

The four principles that follow imply that the core strategy should be relevant, sustainable and ‘Fit for Purpose’ and become part of the NPPF and LDF:
• Positively prepared.
Our observation on the previous Local Plan that insufficient forward planning had been carried in accordance with the Core Strategy which should have been adhered to and we will not be surprised if the same ‘policy’ will prevail. We look forward to the Planning Inspector requesting a coordinated approach and consultation with the community representatives, as the present system is not fit for purpose.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

• Justified.
In view of the aforesaid we do not believe there was any justification to allow more sites to be put forward without clear thinking on assessments being made in respect of the “existing Infrastructure”, and the use of Green Belt land being used instead of Brownfield land and the other issues stated in this document.
The Core Strategy, NPPF and LDF and Localism Act all express that Green Belt land should only be used as a last resort and only under exceptional circumstances, many issues which we have demonstrated have not been addressed sufficiently. Can RDC demonstrate why they are unable to adhere to the rules and regulations designed to safeguard the community.
According to the Localism Act 2011, we have demonstrated that transparency and consultation were lacking with the community. This has to be rectified and included within the proposed Local Plan.
• Effective
The conditions for the development of the 36 Hullbridge sites will not be satisfied for the reasons given above, therefore we consider a complete review of these possible proposed developments and the Core Strategy allows for the community to raise these issues and get into meaningful dialogue with RDC.
• Consistent with National Policy
National policy insists that all the policies stated should be transparent, proper consultation pursued in relations to all the development criteria. We do not believe that proper feasibility studies, risk analysis have been conducted in order to satisfy the requirements of the NPPF and LDF. Most subjects referred to in this presentation will imply reasons for withdrawal, in view of Government directives and regulations listed above.
The Localism Act 2011 Chapter 20. suggested meaningful dialogue with the HRA. Our residents asked what guarantees will be given to HRA that we will be listened to, not merely placing this document on RDC website to satisfy the Planning Inspector requirements. We require RDC Planning/Legal department to clarify.

Clauses 1.18 and 1.19 speaks of ‘community-led planning’ which is of interest to HRA but all our applications and requests for clarification are ignored. We have consistently placed great emphasis on ‘community cohesion’. Which makes for good public awareness. We can produce correspondence to the Parish Council for cohesion in respect to the whole community and help to remove the divisions which exist at present.
HRA have requested support from the Hullbridge Parish Council and indeed our rights should be upheld in accordance with the Localism Act..

Page 5.
Clauses 1.20 and 1.21
How can the RDC ensure that our proposals can be supported for the benefit of the community.
Clause 1.21 Infrastructure Delivery Plan (IDP) and the Community Infrastructure Levy (CIL) will be prepared to set out the circumstances that the CIL will be applied and the key infrastructure that the CIL will seek to fund. The Council will seek to fund this through a ‘Community levy’. This implies that the RDC are not protecting the community. ECC financial planning administration needs reviewing on the subject of ‘contingencies’ which should apply to all categories of infrastructure and other important categories to allow for future planning, maintenance and improvement.

The Essex County Council document “Greater Essex Growth” states that Greater Essex Growth and Infrastructure Framework 2016 is not listed or discussed. The Executive Summary says that Section 106 and ‘Community Infrastructure Levy’ (CIL) will fall way short of expectations and other Government Funding will be in ‘shortfall’ to the tune of £ Billions (report produced by AECOM) who also produced the RDC “Sustainability Analysis”, please explain why they did not cite this issue.
Stakeholder Ref: CP15678E Community Representative Ref: 29007

HRA study of funding under section 106, particularly to fund the local Clinics (£164k recently) which was put to the NHS and RDC fell short of the required sum in view of the increased population. HRA requested consultation to allow co-ordinated conclusions. No surprise this was ignored by all concerned.
The normal LA practices are that a 10 year plan allowing the income to be divided into categories of funding allowing for contingencies for each element of Infrastructure to satisfy needs as they arise, so the question is what have you done with those budgets, as we keep being informed of shortage of funds, perhaps the auditors are allowed to explain how that money was spent. We ask, under ‘The Freedom of Information Act’ why the Hullbridge infrastructure was allowed to deteriorate over at least 50 years.
HRA object to the IDP and CIL because these should be RDC, ECC and Agency obligations to use the contingency funds and not produce more rules which allow the LA to cover up their own accountability inadequacies and should not be an ‘extra’ burden to the community.
If approved, this will set a precedent for other forms of funding from the communities. The community are concerned by this new statement lacking in the Core Strategy and the Land Development Framework. Can you blame the community for showing concern that LA mismanagement of funds fall to the communities having to make good the shortfall wherever they occur.

Page 9. Item 3.2. 36 Sites additional development Land.
The Land Mass measured and stated in this clause we find is out of date because several hectares have already been built on since 2012 which should have been taken into consideration, thus reducing the Land Mass area. Your review and consultation is necessary and we look forward to open discussions in
accordance with the Localism Act.

Section 3. Please refer to our Exhibit A- Development density comparison on pages 14/15.
The total measure of 36 sites = 124 hectares (approximately) which will provide a capacity of 3720 dwellings at minimum 30 dwellings per hectare. The minimum density of 30/60 dwellings per hectare can provide 3720 to 7440 dwellings.

Boundary Line.
Further examination of the same map A indicates that 30.5% of the land lies in the adjoining Rawreth Parish. Please refer to our Exhibits A and B on pages 14-15 and 16 – 20 consecutively.
The result provides the following information:
In our examination of the New Local Plan Document, we are unable to find any explanation for dealing with this ‘division’. Using our previous submission in relation to the Boundary Line indicated on the Ordnance Survey shown and confirmed by the Local Boundary Commission, our correspondence with Rochford District Council requesting clarification on the Parish Council division and the financial implications, they refused to accept the existence of this Boundary line. At a meeting with the developer, we were informed that RDC will allow Council Tax collected by Hullbridge on behalf of Rawreth Parish. Have RDC made the necessary application to LBC for the necessary changes to the Boundary Line and whether or not Rawreth will be amalgamated with Hullbridge at some future date.
The same principle applies with the Boundary Commission England and the National Planning Policy Framework regulations, again we ask for specific dialogue to satisfy the regulations. One of the Green Belt policy purpose is to prevent neighbouring towns/villages from merging into one, Can RDC explain why they seem to have abandoned this policy.

Page 10. Clauses 3.6 to 3.8, Figures 2 and 3. “Travel to work outflows and inflows”.
The travel patterns have changed since 2011 by about 18% with the increase of population. We request a review of the information being given, affecting transport congestion and lack of proper infrastructure.

Page 11. Clauses 3.9 to 3.12. Employment statistics.
We suggest a review is necessary. What guarantees will the prospective developers give to employ local skills.
Stakeholder Ref: CP15678E Community Representative Ref: 29007

Pages 12 and 13. Our Environment. Clause 3.13
Previous Statements made by the Environment Department, Highways & Water Agencies and the HSE suggesting assessments made in 2011 and 2014 were ‘insufficient’ and all future assessments will also fall short of efficiency with funding being used as an excuse to minimise costs giving rise to lack of obligations to this community and to blame Government pressure to satisfy the development quota being used as an excuse to limit the scale of assessments, thus breaching the clauses in the LDF, NPPF and Localism Act.
The same agencies gave evidence to the Planning Inspector that Hullbridge is a ‘sparsely populated’ area. This can be classified as a false statement knowing that Flood water has been a major concern for many years including surface and foul water discharges onto roads and gardens, due to lack of improved drainage facilities and gardens constantly under water. Further land being put forward for development will exacerbate the infrastructure issue. We are informed that RDC do not keep records of ‘Public health’ issues, any complaints are ignored. Foul sewers are grossly overloaded. A full upgrade of the drainage system has always been overdue. This issue should be investigated rigorously by the RDC and it is their responsibility to inform the ECC.

Page 14. Our Communities.
The Hullbridge population count for 2011 census states a population of 6858. HRA support from the community in 2017 suggests 7000 and in 2019 = 7400.
The current development of 500 homes proves an annual population increase from 2019 to 2023 = 9400 population. The growth in the previous 3 decades (census) indicated an average of 2.2% increase. This indicates an average annual increase of 2% per census. This is contrary to the Core Strategy, LDF and the NPPF and the Localism Act that any increase in population should follow the historical line. Hopes rise for a new climate of close Community Consultation.

Page 15 Table 1. Breakdown of 2011 Population Census.
These possible developments will increase the Hullbridge population (see Exhibit B- Population) to 35,900 which will be close to the present Rayleigh population within 15 to 20 years.

Hullbridge, presently with a ‘village status’ will become a Town with a population probably second only to Rayleigh. The Portfolio Holder (Councillor Ian Ward) stated that the Local Plans have changed and it was now paramount to ‘listen’ and closely ‘consult and engage’ with the community, but most people are sceptical that our voices will be heard, and the necessary amendments put forward by the HRA ‘professionals’ will not be heeded. Hullbridge presently consider all verbal utterances are not considered in favour of the community, and no changes are evident except for many of our issues on planning which HRA had to investigate without any RDC help to satisfy the community q & a meetings.

Clause 3.20 Using HRA figures given above we are unable to reconcile with your statement that “the proportion of residents in all demographic ranges will remain ‘stable’. We advise the RDC to review their information and observe the contents of our Exhibit A and B on pages 14/15 and 16-21 provides the necessary calculation, showing exceptional over-population.

Page 16
Clauses 3.21 to 3.25 needs to be reviewed in respect of the statements made being out of date, as the document is prepared using data prescribed in 2011 without fact-finding surveys being conducted to carry out ‘forward planning’ especially with the owner-occupation criteria becoming financially unreliable. With experience of the Public Finance Initiative (PFI) being suspect it will be necessary to return to Council House Building with participation between Local Government and Housing Associations being a prime ‘home provider’ but all motives are suspect.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

Section 4
Page 17 – Spatial Challenges.
Great emphasis is placed on the laws governing the National Planning Policy Framework. We highlight the following to allow you to respond to the Hullbridge Residents Association.
We request you uphold the clauses requiring Consultation with the community Representative such as the HRA with and allowing replies to issues of importance to the community, before finalising the New Local Plan.

Consultative Objections.
We submit our “Consultative Objections” and conform to the NPPF policy namely – that the Local Authority and the ‘Applicants’ must work closely with those directly affected by their proposals to evolve designs that take account of the views of the community.

Brownfield and Greenfield land.

The allocation DPD Document (Feb 2010)- Discussion & Consultative Document on page 1 states that the Council Statement of Community Involvement is committed to Regulations 25 Public Participation in the preparation of Planning for the District (revised 2017). We ask for the right to be properly consulted on this issue that the allocation document has no brownfield sites identified as given in our Exhibit B.

Section 5.
Page 24. Clause 5.1. Our Vision and Strategic Objectives.
HRA experience gained over 9 years of deliberations over the Hullbridge ‘developments’ and Local Plans, that this has not been a success as the majority of the 185 issues submitted in 2014, not being satisfied, and with alliances formed with other localities the same view is expressed. The fact that you did not respond indicates that we are right on all the issues submitted to you and hope the Planning Inspector will take this into account in respect of all future “Consultation”.
We hope that the Planning Inspector takes into account the atmosphere of distrust by the community.

Clause 5.4 Our current Vision
HRA disagree that what is being prescribed on the Hullbridge Plan will allow the community to have the best quality of life, when there is at least 20 years of disruption to look forward to, which will blight our lives. Whole sale development is taking place with major clauses in the NPPF being disregarded.
A “Considerate Contractor Scheme Notice must be a requirement for all contractors to observe the rules towards the community.

Page 26. Clause 5.10. Rochford District 2037. Our Society
We disagree with the statement made that’ the green infrastructure network across the district has been enhanced to support our population. Many hectares of Green Belt Land are being allowed to be developed disregarding all the clauses which are supposed to protect the Green Belt and Government directives. Articles written by the Campaign to Protect Rural England (CPRE) bear witness to the contrary and the community remain sceptical about the final outcome.
The community believe that the homes will be for the over- burgeoning populace of London, not of Essex. We fail to see how you can demonstrate the indigenous population expansion taking priority.

Page 28. Cl. 5.11. Strategic Objective 13. Flood.
Experience gained by the lack of proper assessments on flood, disregarding all the issues provided to you in 2013. Decisions are being made according to financial constraints.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

RDC now have a recipe for disaster in an area naturally susceptible to surface water discharge from the ‘Rayleigh Heights’ about 65m above ground level and surrounding areas of vulnerable Watery Lane.


Page 29. Strategic Priority 5. Climate change.
The Hullbridge community are concerned that the information provided by various Agencies and Insurance Companies that the 1:100 flood incident is flawed and is more likely to be a maximum 1:25 due to Climate change. There is scepticism that the LA will help change the law and this will be detrimental to the community at large. Sea levels have officially been recorded as rising some 150mm above sea level from the beginning of this century and are forecast to rise by 500mm before the end of this century.

Section 6.
Pages 32 to 38. Clauses 6.8 to 6.29. Tables 2 to 4.
Advance notice. Property Insurance.
The potential Property Insurance costs against ‘flood risk’ and ‘subsidence in these areas, can range from £2500 to £5000. per household depending on the risk analysis.
An exercise on Post Codes SS5 reveals that using the ‘Hawkeye’ system determining the level of associated risks such as flood, subsidence etc., the combined results show that in both instances, subsidence is Red, meaning these are perils which will either be excluded or a large excess applied in respect of subsidence – usually £2,500.00 (£1000.00 being ‘Standard’) and for any areas susceptible to flood, without protection barriers or flood defences will increase the Cost Risk to £5,000.00 per property making ‘flood excess’ a priority and no claims accepted by the Insurance Companies if this is applied to development in flood areas.

Page 38 to 40. Clauses 6.29 to 6.33. Homes for purchase and Affordable Homes.
This document was obviously written before the changes which have taken place in the financial industry and Government policies. The change in ‘affordability’ has not been fully considered. We advise you to review and amend this statement accordingly.
How can you demonstrate the ‘affordability’ during this financial climate, which are likely to continue for the next 10 years, irrespective of the incentives given on stamp duty and directives to the lending institutions? Most younger adults will have great difficulty to purchase homes and maintain mortgage payments.

Table 5 Rochford District- Settlement Hierarchy.
We have always had an issue with the infringement of the Green Belt. Most of the present developments recently completed or under construction are being built on Green Belt land disregarding brownfield sites. We suspect that the new Land Development Framework document questions the need to build on the green belt land. Our Exhibit B presents you with our statements on your LDF

Page 45. Clause 6.48. Housing Density Options .
Earlier we provided calculations for the lowest density of development per hectare, It is evident that the option may be for up to 60 homes per hectare which will increase the incentive provided by the Government and risk the long term harmony in the community and will cause even greater strain and stress on the Hullbridge infrastructure and the community.
RDC must take advantage of requesting funds from the Government announcement of £866m funds from the Housing Infrastructure Fund (HIF) to enable the existing Hullbridge infrastructure be brought up to standard, on the grounds that the previous planning regime’s over the last 30 years have been negligent in dealing with the existing infrastructure as suggested on page 6. Clause 1.21.



Stakeholder Ref: CP15678E Community Representative Ref: 29007


Section 8.
Local Highways Capacity and Infrastructure. Clause 8.3 LDF Development Management Submission Document- Section 5- Transport page 73. Improvements to local road network
The only access points to get to Hullbridge is Lower Road and Hullbridge Road. Watery lane should not be considered as a main thoroughfare and we despair that the Essex County Council, Rochford District Council and the Agencies seem to ignore this fact. We want the Planning Inspector to review his statement in the ‘Planning approval’ given in 2014 that RDC consult with HRA on the feasibility for improvement of this Lane, as it is not ‘fit for purpose’.

Highways Risk Analysis.
HRA are concerned that a proper Highways Risk Analysis has not been carried out by the Core Strategy, NPPF and LDF documents. Further consideration must be given for ‘transparency’ as stated in The Localism Act (2011). Recent replacement of 50 years old Gas services emphasises the disruption which
will be caused by both existing and future construction work. County and Local Authorities please take note.

Watery Lane, is in urgent need of improvement and HRA have corresponded with RDC, ECC and all the Agencies showing Watery Lane and Hullbridge Road are identified as traffic congestion points, in clauses 8.13 to 8.15.
We request that RDC/ECC/Agencies contact the SAT NAV services to remove Watery Lane as a general thoroughfare and emphasise this is “weight restricted” and ‘width restrictive’ and speed limits reviewed with adequate signage..
This lane is too narrow for any vehicles over 30 cwt. The lane is without a public footpath making this lane a health and safety issue which needs urgent rectification. HRA suggest that this section of the document should be reviewed, particularly as the Planning Inspector acknowledged HRA argument that Watery Lane is not ‘fit for purpose’, we reject the statement that Watery Lane is NOT part of the “Strategic Highways Network” please review, amend and highlight for the Planning Inspector to view..

Accessibility to Services. Hullbridge has many un-adopted, single lane and unmade roads making access difficult for the Fire, Police, Refuse, Ambulance and general delivery services and will not be suitable for constant construction site traffic for next 20 years a covenant should be inserted to allow the ECC and their Agencies to make urgent contingencies before the matter gets worse as expansion proceeds..

Fire Hydrants. Hullbridge only has 8 Fire Hydrants to serve the whole village, which is considered inadequate for the fire services.


Page 85 - 90. Clause 8.22 to 8.37. Sustainable Travel.
The transport system is being overhauled to reduce the number of buses serving the communities and the frequency, if this carries on, there will be future major problems. Please refer to LDF Allocations Submission Document Page 60 Cl 3.177/178.

Page 87. Clause 8.31 Rayleigh Air Quality.
Reading this clause we are not confident that something will be done to provide good quality air. It was reported in the media, that dangerous levels of nitrous oxide caused by diesel fumes are being recorded in and around the Rayleigh area. Air quality is lacking in both depth and detail which means the RDC ‘evidence base’ on the subject of traffic, is lacking. Please explain your remedy? This pollution has been apparent for many years but ignored. The community now demand action to remedy this issue.

Stakeholder Ref: CP15678E Community Representative Ref: 29007


Page 92 to 96. Clause 8.45 to 8.58. Water and Flood Risk management.
Flood
At times of flood (frequent - 25 times in 5 years), in Watery Lane, has resulted in many accidents, causing ‘gridlock’ to the whole local traffic system in Hullbridge and surrounding areas. Drainage is unable to cope with excess flood water resulting in overflow of excrement and water into roads and gardens and cross-surging foul water and surface water services

Page 96- 98. Clause 8.59 – 8.66. Renewable Energy Generation.
We agree about the ‘renewable energy’ ‘dream’ from all sources and accept there is natural course of events to be taken for the sake of the concerns on Global Environment. It is the political challenges which become the difficult part to address. Perhaps Political will may help.

Page 98-100. Clause 8.67- 8.75. Planning Obligations and Standard Charges.
Local Authorities ignore the observations and pleas made to review and observe the standards laid down by the NPPF, Core Strategy and LDDF to allow ‘proper’ consultation with the community representatives.
The NPPF guidelines on all planning obligations suggest that the 3 tests as set out, must pass:
1 Necessary to make the development acceptable in planning terms.
2 Directly related to the development.
3 Fairly and reasonable related in scale and kind to the development.
The community want an action plan to allow meaningful consultation with the community.

Section 9 Supporting Health, Community and Culture.
Page 101- 120. Clauses 9.1 – 9.61. Health Impact assessment- Cl 3.186
We (HRA) brought to the authorities’ attention various anomalies in the financial accountability in assessing the “Contributions” without giving considerations to contingency for increases in inflation and time related uplift. HRA are happy to be consulted in the future.
HRA investigated the Health Provision indicated in Section 106 ‘contributions and concentrated on the sum stated to be for the Riverside Medical Centre on Ferry Road and found the sum stated to be inadequate. We fear the same decisions may be made for the foreseeable future. As HRA have been active on this issue it would be in the interests of all parties to consult and agree a course of action.

Section 10 Protecting and Enhancing our Environment.
Page 121 - Clause 10.1 to 10.4
General planning policy of the NPPF suggests minimising vulnerability and provide resilience to climate change impacts. RDC and ECC must provide a course of actions.

Page 121 – 141. Clause 10.5 – 10.72 Green Belt
We agree the purposes of the NPPF clause 10.7-10.8 in that the 5 purposes of the Green Belt set out to:
1. Check the unrestricted sprawl of large built up areas
2. Prevent neighbouring towns merging into one another.
3. Assist in safeguarding the countryside from ‘encroachment.
4. Preserve the setting and special character of historic towns.
5. Assist in urban regeneration, by encouraging the recycling of derelict and other urban land ie Brownfield Sites. Inappropriate development. (Page 122. Clause 10.8) Specifically states that the construction of new buildings in the Green Belt is generally considered to be inappropriate development.
The Hullbridge Residents Association respectively request that Rochford District Council adhere to these policies and review the New Local Plan Document. It may be appropriate to classify this as “Special Measures” and allow the intervention of a Planning Inspector to adjudicate.

Stakeholder Ref: CP15678E Community Representative Ref: 29007

Section 11. Detailed Policy Considerations. Pages 142- 165
Page 142. Clause 11.2 Mix of Affordable Homes

In HRA discussions with a developer we were advised that the RDC stated that the Core Strategy and the Land Development Framework were ‘out of date’ therefore some clauses were not applicable.
The same situation applied to discussions when applied to the Localism Act. The Core Strategy and the NPPF are evident in many statements in this new Local Plan document, so, we consider there has been no change in the above main documents, action is necessary.

Page 155. Clause 11.45 Brownfield Sites. HRA have taken into account clauses 11.45/ 46 and taken into consideration that all Brownfield sites must have priority. NPPF paragraph 89 and Policy DM10 on brownfield development should be an over-riding factor when producing these documents. We refer you to the ‘ambitious’ clauses stipulated in the LDF Management Submission Document- Clause 3 page 33- The Green Belt and Countryside – Vision. Short term. The first paragraph stipulates the “openness and character” of the Rochford Green Belt continues to be protected. Constant reference by our MP Mark Francois has been ignored which places him in an awkward position.

Page 164. Contaminated land. Cl 11.77 to 11.81. Specific example of for
Nevendon Yard Breakers Yard, Lower Road, Hullbridge. Proposed 90 units.
This site is contaminated over a 70 year period and the costs of eradication will be high. The outline application plans are presently delayed for that reason while a historical document is being prepared.

LOCALISM ACT 2011 chapter 20. Item 2.1 (5th bullet point)
The ‘Localism Act’ was brought into force in 2011, the community did not have the opportunity to apply the clauses of this act. This act stipulates that the Local Community has: the ‘right to challenge’ (Part 5, Chapter 2, Clauses 81 to 86).


End of Appeal For Withdrawal.

Dear Sir,
Re: Stakeholder: Reference CP15678E. Community Representative No. 29007.

New Local Plan 2021 Consultation. Issues and Options Documents & Statement of Community Involvement and the Spatial Options documents.

We request Rochford District Council to invite the Government Planning Inspector to find that the New Local Plan 2021 must be withdrawn for reasons mentioned below.
In our consideration the Map A, on the basis of the relevant Legislation Guidance in the National Planning Policy Framework is not:
Positively Prepared
Justified
Effective
Consistent with National Policy

There are sufficient clauses in the NPPF, LDF and Localism Act which stipulate that all issues must be considered including Infrastructure and in areas environmentally threatened as shown in the Environment Agency and the Insurance Company data (Flood maps). It is imperative proper assessments be made in accordance with the NPPF regulations such as Flood, Road Network, Proximity to rivers and all issues set out below. Our experience from the current Malyons Lane large development that our SCI will be ignored again unless we have support from our MP Mark Francois and all the Councillors who are continually proud to state they are Community minded.

The Hullbridge Residents Association have viewed the Local Development Framework Evidence Base and note that the contents are a repeat of the documents issued in 2015 as are the documents mentioned above
Along with the accompanying Integrated Impact Assessment.

Section 1. Introduction
1.1 States this is a review document of the original adoption in 2016, now presented in repetition but revised in 2015 and 2017 (for 2021).

We understand the need for additional homes, but we are concerned that ‘Infrastructure is not given priority as stated by our MP Mark Francois and indeed Government directives, particularly the existing infrastructure but continually being ignored.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

Page 1. Clause 1.2

HRA produced and delivered to RDC a 45-page document on the Core Strategy, Land Development Framework (LDF), National Planning Policy Framework (NPPF) and Localism Act for a development in progress and submitted some 525 issues in the planning documents presented by RDC without a proper response.
The clauses about Community Consultation being important is just a paper exercise to convince the Planning Inspector that the community support all the data produced.

HRA 9 years of experience has shown RDC and Councillors lack of the understanding or interpretation of Community Involvement, proper consultation and transparency, and fear another regretful experience with all sites being put forward for possible development. Having spoken to some Councillors they state that these site will not necessarily be approved to allow planning applications, but past experience does not provide any confidence that the community issues will be taken into account..
We make a plea to the Government Planning Inspector to investigate reasons why the community are ignored in proper consultation.

36 Sites.
We demonstrate our reasons for our rejection of many sites (stated in our document marked “Exhibit B- Issues and Options”) until the subject of the infrastructure (in all aspects- including existing) are reviewed This is an important subject and we extend our Plea to the Planning Inspector to set this review in motion and allow full participation by the Community Representative.

We consider the following clauses of the NPPF and Core Strategy must be applied:

NPFF 3– Core Planning Principles. Pages 1, 5-6, Clauses 1-2, 6-17.
NPPF 4 – Promoting Sustainable Transport.
NPPF 5 – Supporting high quality communications infrastructure. With roads/transport a priority.
NPPF 6 – Delivering a wide choice of high quality homes.
NPPF 7- Requiring Good Design.
NPPF 8 – Promoting Healthy communities.
NPPF 9 - Protecting the Green Belt land.
NPPF 10- Meeting the Challenge of Climate Change, Flooding & Coastal change.
NPPF 11- Conserving and enhancing the future environment.
NPPF Plan Making – Local Plans (p. 37).
NPPF Using a Proportionate evidence base- (p. 38).
NPPF Ensuring Viability and Deliverability- ( p. 41).
NPPF Decision taking – Pre-application engagement & front loading, (p. 45).
Technical Guidance to the NPPF- Flood risk on page 2. Sequential and Exceptional Tests p. 3 to 7.
NPPF - Sequential and Exceptional Tests –

Drainage
Sustainable drainage systems;
We have submitted documents in respect of the existing drainage system needing substantial improvements prior to any links being provided to the new developments and should be part of the necessary required Infrastructure works we have continually highlighted that the present system is not ‘fit for purpose’, but this was ignored. RDC are duty bound to inform ECC (RDC state that this is not their responsibility.


Stakeholder Ref: CP15678E Community Representative Ref: 29007


Page 2.
Clause 1.7 Statement of Community Involvement.
Having been disappointed with the first Statement of Community Involvement document in 2013 and 2016 we take the clause 1.7 on page 2 seriously and look forward to proper ‘consultation’ by RDC, and not use our submission purely as a ‘tick-box’ exercise to prove to the Planning Inspector that the regulations are observed and, our views have been taken into account but we have not seen these issues progressed to amendments in the Local Plan. HRA represent the Hullbridge community and have the right for engagement as stated in the NPPF and the Localism Act.

Clauses 1.8 & 1.9.
A plan indicating 36 additional sites on Map A in Hullbridge along with a further 6 sites not identified on Map A. Please refer to our Exhibit A on pages 14 and 15.

Clause 1.10 is of special interest as it mentions “on-going consultation” at every stage. We did not have the opportunity to discuss ‘The Draft Scoping Report’ which was published on the RDC websites, and the residents, businesses and other ‘stakeholders’ on the RDC mailing list were not consulted (HRA is a Stakeholder and Representative)- continually ignored by RDC- indeed HRA have correspondence relating to this issue that “if we did not like it we should consider litigation’.

Clause 1.14 on page 4 is of special interest to us as we placed emphasis on the Localism Act (2011) with the Managing Director of RDC and were told that the Localism Act was irrelevant. Why is it now more relevant than before? We request this ‘Act’ to be included as it supports Human Rights.

Clause 1.16. Only one ‘drop-in session’ was set up at Hullbridge Community Centre on 24/8/21. The attendance was low, HRA committee had 9 committee members present who asked questions and had responses which do not reflect the issues put forward in this ‘Plea’. One answer took us by surprise, that the Essex Design Guide which we have referred to throughout has been replaced by Rochford own Design Guide. When we consider the reduced staff levels with some unqualified planning staff it leads us to believe that this design guide will be subject to much criticism. We hope the Government Inspector will take this into account.

Planning law requires that “Call for Sites” which falls part of the development plan in accordance with the Regulations Governing Neighbourhood Planning Laws- NPPF 6 - Plans and Strategies – Part 6, Chapter 1, clauses 109 to 113, allows for Neighbourhood Planning – Part 6, chapter 3, clauses 116 to 121., and gives the community the right to Consultation – Part 6, chapter 4, clause 122. We challenge RDC to approve our application for this Neighbourhood Planning Group and a Statutory Consultee status which will also be an asset to the Hullbridge Parish Council. No explanation is given for reasons why we are not allowed to have consultation to give us good reasons why the regulations are not being properly debated and a conclusion found. This attitude denies community skills and professions adequately proven over 9 years of hard work, not acknowledged.

The four principles that follow imply that the core strategy should be relevant, sustainable and ‘Fit for Purpose’ and become part of the NPPF and LDF:
• Positively prepared.
Our observation on the previous Local Plan that insufficient forward planning had been carried in accordance with the Core Strategy which should have been adhered to and we will not be surprised if the same ‘policy’ will prevail. We look forward to the Planning Inspector requesting a coordinated approach and consultation with the community representatives, as the present system is not fit for purpose.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

• Justified.
In view of the aforesaid we do not believe there was any justification to allow more sites to be put forward without clear thinking on assessments being made in respect of the “existing Infrastructure”, and the use of Green Belt land being used instead of Brownfield land and the other issues stated in this document.
The Core Strategy, NPPF and LDF and Localism Act all express that Green Belt land should only be used as a last resort and only under exceptional circumstances, many issues which we have demonstrated have not been addressed sufficiently. Can RDC demonstrate why they are unable to adhere to the rules and regulations designed to safeguard the community.
According to the Localism Act 2011, we have demonstrated that transparency and consultation were lacking with the community. This has to be rectified and included within the proposed Local Plan.
• Effective
The conditions for the development of the 36 Hullbridge sites will not be satisfied for the reasons given above, therefore we consider a complete review of these possible proposed developments and the Core Strategy allows for the community to raise these issues and get into meaningful dialogue with RDC.
• Consistent with National Policy
National policy insists that all the policies stated should be transparent, proper consultation pursued in relations to all the development criteria. We do not believe that proper feasibility studies, risk analysis have been conducted in order to satisfy the requirements of the NPPF and LDF. Most subjects referred to in this presentation will imply reasons for withdrawal, in view of Government directives and regulations listed above.
The Localism Act 2011 Chapter 20. suggested meaningful dialogue with the HRA. Our residents asked what guarantees will be given to HRA that we will be listened to, not merely placing this document on RDC website to satisfy the Planning Inspector requirements. We require RDC Planning/Legal department to clarify.

Clauses 1.18 and 1.19 speaks of ‘community-led planning’ which is of interest to HRA but all our applications and requests for clarification are ignored. We have consistently placed great emphasis on ‘community cohesion’. Which makes for good public awareness. We can produce correspondence to the Parish Council for cohesion in respect to the whole community and help to remove the divisions which exist at present.
HRA have requested support from the Hullbridge Parish Council and indeed our rights should be upheld in accordance with the Localism Act..

Page 5.
Clauses 1.20 and 1.21
How can the RDC ensure that our proposals can be supported for the benefit of the community.
Clause 1.21 Infrastructure Delivery Plan (IDP) and the Community Infrastructure Levy (CIL) will be prepared to set out the circumstances that the CIL will be applied and the key infrastructure that the CIL will seek to fund. The Council will seek to fund this through a ‘Community levy’. This implies that the RDC are not protecting the community. ECC financial planning administration needs reviewing on the subject of ‘contingencies’ which should apply to all categories of infrastructure and other important categories to allow for future planning, maintenance and improvement.

The Essex County Council document “Greater Essex Growth” states that Greater Essex Growth and Infrastructure Framework 2016 is not listed or discussed. The Executive Summary says that Section 106 and ‘Community Infrastructure Levy’ (CIL) will fall way short of expectations and other Government Funding will be in ‘shortfall’ to the tune of £ Billions (report produced by AECOM) who also produced the RDC “Sustainability Analysis”, please explain why they did not cite this issue.
Stakeholder Ref: CP15678E Community Representative Ref: 29007

HRA study of funding under section 106, particularly to fund the local Clinics (£164k recently) which was put to the NHS and RDC fell short of the required sum in view of the increased population. HRA requested consultation to allow co-ordinated conclusions. No surprise this was ignored by all concerned.
The normal LA practices are that a 10 year plan allowing the income to be divided into categories of funding allowing for contingencies for each element of Infrastructure to satisfy needs as they arise, so the question is what have you done with those budgets, as we keep being informed of shortage of funds, perhaps the auditors are allowed to explain how that money was spent. We ask, under ‘The Freedom of Information Act’ why the Hullbridge infrastructure was allowed to deteriorate over at least 50 years.
HRA object to the IDP and CIL because these should be RDC, ECC and Agency obligations to use the contingency funds and not produce more rules which allow the LA to cover up their own accountability inadequacies and should not be an ‘extra’ burden to the community.
If approved, this will set a precedent for other forms of funding from the communities. The community are concerned by this new statement lacking in the Core Strategy and the Land Development Framework. Can you blame the community for showing concern that LA mismanagement of funds fall to the communities having to make good the shortfall wherever they occur.

Page 9. Item 3.2. 36 Sites additional development Land.
The Land Mass measured and stated in this clause we find is out of date because several hectares have already been built on since 2012 which should have been taken into consideration, thus reducing the Land Mass area. Your review and consultation is necessary and we look forward to open discussions in
accordance with the Localism Act.

Section 3. Please refer to our Exhibit A- Development density comparison on pages 14/15.
The total measure of 36 sites = 124 hectares (approximately) which will provide a capacity of 3720 dwellings at minimum 30 dwellings per hectare. The minimum density of 30/60 dwellings per hectare can provide 3720 to 7440 dwellings.

Boundary Line.
Further examination of the same map A indicates that 30.5% of the land lies in the adjoining Rawreth Parish. Please refer to our Exhibits A and B on pages 14-15 and 16 – 20 consecutively.
The result provides the following information:
In our examination of the New Local Plan Document, we are unable to find any explanation for dealing with this ‘division’. Using our previous submission in relation to the Boundary Line indicated on the Ordnance Survey shown and confirmed by the Local Boundary Commission, our correspondence with Rochford District Council requesting clarification on the Parish Council division and the financial implications, they refused to accept the existence of this Boundary line. At a meeting with the developer, we were informed that RDC will allow Council Tax collected by Hullbridge on behalf of Rawreth Parish. Have RDC made the necessary application to LBC for the necessary changes to the Boundary Line and whether or not Rawreth will be amalgamated with Hullbridge at some future date.
The same principle applies with the Boundary Commission England and the National Planning Policy Framework regulations, again we ask for specific dialogue to satisfy the regulations. One of the Green Belt policy purpose is to prevent neighbouring towns/villages from merging into one, Can RDC explain why they seem to have abandoned this policy.

Page 10. Clauses 3.6 to 3.8, Figures 2 and 3. “Travel to work outflows and inflows”.
The travel patterns have changed since 2011 by about 18% with the increase of population. We request a review of the information being given, affecting transport congestion and lack of proper infrastructure.

Page 11. Clauses 3.9 to 3.12. Employment statistics.
We suggest a review is necessary. What guarantees will the prospective developers give to employ local skills.
Stakeholder Ref: CP15678E Community Representative Ref: 29007

Pages 12 and 13. Our Environment. Clause 3.13
Previous Statements made by the Environment Department, Highways & Water Agencies and the HSE suggesting assessments made in 2011 and 2014 were ‘insufficient’ and all future assessments will also fall short of efficiency with funding being used as an excuse to minimise costs giving rise to lack of obligations to this community and to blame Government pressure to satisfy the development quota being used as an excuse to limit the scale of assessments, thus breaching the clauses in the LDF, NPPF and Localism Act.
The same agencies gave evidence to the Planning Inspector that Hullbridge is a ‘sparsely populated’ area. This can be classified as a false statement knowing that Flood water has been a major concern for many years including surface and foul water discharges onto roads and gardens, due to lack of improved drainage facilities and gardens constantly under water. Further land being put forward for development will exacerbate the infrastructure issue. We are informed that RDC do not keep records of ‘Public health’ issues, any complaints are ignored. Foul sewers are grossly overloaded. A full upgrade of the drainage system has always been overdue. This issue should be investigated rigorously by the RDC and it is their responsibility to inform the ECC.

Page 14. Our Communities.
The Hullbridge population count for 2011 census states a population of 6858. HRA support from the community in 2017 suggests 7000 and in 2019 = 7400.
The current development of 500 homes proves an annual population increase from 2019 to 2023 = 9400 population. The growth in the previous 3 decades (census) indicated an average of 2.2% increase. This indicates an average annual increase of 2% per census. This is contrary to the Core Strategy, LDF and the NPPF and the Localism Act that any increase in population should follow the historical line. Hopes rise for a new climate of close Community Consultation.

Page 15 Table 1. Breakdown of 2011 Population Census.
These possible developments will increase the Hullbridge population (see Exhibit B- Population) to 35,900 which will be close to the present Rayleigh population within 15 to 20 years.

Hullbridge, presently with a ‘village status’ will become a Town with a population probably second only to Rayleigh. The Portfolio Holder (Councillor Ian Ward) stated that the Local Plans have changed and it was now paramount to ‘listen’ and closely ‘consult and engage’ with the community, but most people are sceptical that our voices will be heard, and the necessary amendments put forward by the HRA ‘professionals’ will not be heeded. Hullbridge presently consider all verbal utterances are not considered in favour of the community, and no changes are evident except for many of our issues on planning which HRA had to investigate without any RDC help to satisfy the community q & a meetings.

Clause 3.20 Using HRA figures given above we are unable to reconcile with your statement that “the proportion of residents in all demographic ranges will remain ‘stable’. We advise the RDC to review their information and observe the contents of our Exhibit A and B on pages 14/15 and 16-21 provides the necessary calculation, showing exceptional over-population.

Page 16
Clauses 3.21 to 3.25 needs to be reviewed in respect of the statements made being out of date, as the document is prepared using data prescribed in 2011 without fact-finding surveys being conducted to carry out ‘forward planning’ especially with the owner-occupation criteria becoming financially unreliable. With experience of the Public Finance Initiative (PFI) being suspect it will be necessary to return to Council House Building with participation between Local Government and Housing Associations being a prime ‘home provider’ but all motives are suspect.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

Section 4
Page 17 – Spatial Challenges.
Great emphasis is placed on the laws governing the National Planning Policy Framework. We highlight the following to allow you to respond to the Hullbridge Residents Association.
We request you uphold the clauses requiring Consultation with the community Representative such as the HRA with and allowing replies to issues of importance to the community, before finalising the New Local Plan.

Consultative Objections.
We submit our “Consultative Objections” and conform to the NPPF policy namely – that the Local Authority and the ‘Applicants’ must work closely with those directly affected by their proposals to evolve designs that take account of the views of the community.

Brownfield and Greenfield land.

The allocation DPD Document (Feb 2010)- Discussion & Consultative Document on page 1 states that the Council Statement of Community Involvement is committed to Regulations 25 Public Participation in the preparation of Planning for the District (revised 2017). We ask for the right to be properly consulted on this issue that the allocation document has no brownfield sites identified as given in our Exhibit B.

Section 5.
Page 24. Clause 5.1. Our Vision and Strategic Objectives.
HRA experience gained over 9 years of deliberations over the Hullbridge ‘developments’ and Local Plans, that this has not been a success as the majority of the 185 issues submitted in 2014, not being satisfied, and with alliances formed with other localities the same view is expressed. The fact that you did not respond indicates that we are right on all the issues submitted to you and hope the Planning Inspector will take this into account in respect of all future “Consultation”.
We hope that the Planning Inspector takes into account the atmosphere of distrust by the community.

Clause 5.4 Our current Vision
HRA disagree that what is being prescribed on the Hullbridge Plan will allow the community to have the best quality of life, when there is at least 20 years of disruption to look forward to, which will blight our lives. Whole sale development is taking place with major clauses in the NPPF being disregarded.
A “Considerate Contractor Scheme Notice must be a requirement for all contractors to observe the rules towards the community.

Page 26. Clause 5.10. Rochford District 2037. Our Society
We disagree with the statement made that’ the green infrastructure network across the district has been enhanced to support our population. Many hectares of Green Belt Land are being allowed to be developed disregarding all the clauses which are supposed to protect the Green Belt and Government directives. Articles written by the Campaign to Protect Rural England (CPRE) bear witness to the contrary and the community remain sceptical about the final outcome.
The community believe that the homes will be for the over- burgeoning populace of London, not of Essex. We fail to see how you can demonstrate the indigenous population expansion taking priority.

Page 28. Cl. 5.11. Strategic Objective 13. Flood.
Experience gained by the lack of proper assessments on flood, disregarding all the issues provided to you in 2013. Decisions are being made according to financial constraints.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

RDC now have a recipe for disaster in an area naturally susceptible to surface water discharge from the ‘Rayleigh Heights’ about 65m above ground level and surrounding areas of vulnerable Watery Lane.


Page 29. Strategic Priority 5. Climate change.
The Hullbridge community are concerned that the information provided by various Agencies and Insurance Companies that the 1:100 flood incident is flawed and is more likely to be a maximum 1:25 due to Climate change. There is scepticism that the LA will help change the law and this will be detrimental to the community at large. Sea levels have officially been recorded as rising some 150mm above sea level from the beginning of this century and are forecast to rise by 500mm before the end of this century.

Section 6.
Pages 32 to 38. Clauses 6.8 to 6.29. Tables 2 to 4.
Advance notice. Property Insurance.
The potential Property Insurance costs against ‘flood risk’ and ‘subsidence in these areas, can range from £2500 to £5000. per household depending on the risk analysis.
An exercise on Post Codes SS5 reveals that using the ‘Hawkeye’ system determining the level of associated risks such as flood, subsidence etc., the combined results show that in both instances, subsidence is Red, meaning these are perils which will either be excluded or a large excess applied in respect of subsidence – usually £2,500.00 (£1000.00 being ‘Standard’) and for any areas susceptible to flood, without protection barriers or flood defences will increase the Cost Risk to £5,000.00 per property making ‘flood excess’ a priority and no claims accepted by the Insurance Companies if this is applied to development in flood areas.

Page 38 to 40. Clauses 6.29 to 6.33. Homes for purchase and Affordable Homes.
This document was obviously written before the changes which have taken place in the financial industry and Government policies. The change in ‘affordability’ has not been fully considered. We advise you to review and amend this statement accordingly.
How can you demonstrate the ‘affordability’ during this financial climate, which are likely to continue for the next 10 years, irrespective of the incentives given on stamp duty and directives to the lending institutions? Most younger adults will have great difficulty to purchase homes and maintain mortgage payments.

Table 5 Rochford District- Settlement Hierarchy.
We have always had an issue with the infringement of the Green Belt. Most of the present developments recently completed or under construction are being built on Green Belt land disregarding brownfield sites. We suspect that the new Land Development Framework document questions the need to build on the green belt land. Our Exhibit B presents you with our statements on your LDF

Page 45. Clause 6.48. Housing Density Options .
Earlier we provided calculations for the lowest density of development per hectare, It is evident that the option may be for up to 60 homes per hectare which will increase the incentive provided by the Government and risk the long term harmony in the community and will cause even greater strain and stress on the Hullbridge infrastructure and the community.
RDC must take advantage of requesting funds from the Government announcement of £866m funds from the Housing Infrastructure Fund (HIF) to enable the existing Hullbridge infrastructure be brought up to standard, on the grounds that the previous planning regime’s over the last 30 years have been negligent in dealing with the existing infrastructure as suggested on page 6. Clause 1.21.



Stakeholder Ref: CP15678E Community Representative Ref: 29007


Section 8.
Local Highways Capacity and Infrastructure. Clause 8.3 LDF Development Management Submission Document- Section 5- Transport page 73. Improvements to local road network
The only access points to get to Hullbridge is Lower Road and Hullbridge Road. Watery lane should not be considered as a main thoroughfare and we despair that the Essex County Council, Rochford District Council and the Agencies seem to ignore this fact. We want the Planning Inspector to review his statement in the ‘Planning approval’ given in 2014 that RDC consult with HRA on the feasibility for improvement of this Lane, as it is not ‘fit for purpose’.

Highways Risk Analysis.
HRA are concerned that a proper Highways Risk Analysis has not been carried out by the Core Strategy, NPPF and LDF documents. Further consideration must be given for ‘transparency’ as stated in The Localism Act (2011). Recent replacement of 50 years old Gas services emphasises the disruption which
will be caused by both existing and future construction work. County and Local Authorities please take note.

Watery Lane, is in urgent need of improvement and HRA have corresponded with RDC, ECC and all the Agencies showing Watery Lane and Hullbridge Road are identified as traffic congestion points, in clauses 8.13 to 8.15.
We request that RDC/ECC/Agencies contact the SAT NAV services to remove Watery Lane as a general thoroughfare and emphasise this is “weight restricted” and ‘width restrictive’ and speed limits reviewed with adequate signage..
This lane is too narrow for any vehicles over 30 cwt. The lane is without a public footpath making this lane a health and safety issue which needs urgent rectification. HRA suggest that this section of the document should be reviewed, particularly as the Planning Inspector acknowledged HRA argument that Watery Lane is not ‘fit for purpose’, we reject the statement that Watery Lane is NOT part of the “Strategic Highways Network” please review, amend and highlight for the Planning Inspector to view..

Accessibility to Services. Hullbridge has many un-adopted, single lane and unmade roads making access difficult for the Fire, Police, Refuse, Ambulance and general delivery services and will not be suitable for constant construction site traffic for next 20 years a covenant should be inserted to allow the ECC and their Agencies to make urgent contingencies before the matter gets worse as expansion proceeds..

Fire Hydrants. Hullbridge only has 8 Fire Hydrants to serve the whole village, which is considered inadequate for the fire services.


Page 85 - 90. Clause 8.22 to 8.37. Sustainable Travel.
The transport system is being overhauled to reduce the number of buses serving the communities and the frequency, if this carries on, there will be future major problems. Please refer to LDF Allocations Submission Document Page 60 Cl 3.177/178.

Page 87. Clause 8.31 Rayleigh Air Quality.
Reading this clause we are not confident that something will be done to provide good quality air. It was reported in the media, that dangerous levels of nitrous oxide caused by diesel fumes are being recorded in and around the Rayleigh area. Air quality is lacking in both depth and detail which means the RDC ‘evidence base’ on the subject of traffic, is lacking. Please explain your remedy? This pollution has been apparent for many years but ignored. The community now demand action to remedy this issue.

Stakeholder Ref: CP15678E Community Representative Ref: 29007


Page 92 to 96. Clause 8.45 to 8.58. Water and Flood Risk management.
Flood
At times of flood (frequent - 25 times in 5 years), in Watery Lane, has resulted in many accidents, causing ‘gridlock’ to the whole local traffic system in Hullbridge and surrounding areas. Drainage is unable to cope with excess flood water resulting in overflow of excrement and water into roads and gardens and cross-surging foul water and surface water services

Page 96- 98. Clause 8.59 – 8.66. Renewable Energy Generation.
We agree about the ‘renewable energy’ ‘dream’ from all sources and accept there is natural course of events to be taken for the sake of the concerns on Global Environment. It is the political challenges which become the difficult part to address. Perhaps Political will may help.

Page 98-100. Clause 8.67- 8.75. Planning Obligations and Standard Charges.
Local Authorities ignore the observations and pleas made to review and observe the standards laid down by the NPPF, Core Strategy and LDDF to allow ‘proper’ consultation with the community representatives.
The NPPF guidelines on all planning obligations suggest that the 3 tests as set out, must pass:
1 Necessary to make the development acceptable in planning terms.
2 Directly related to the development.
3 Fairly and reasonable related in scale and kind to the development.
The community want an action plan to allow meaningful consultation with the community.

Section 9 Supporting Health, Community and Culture.
Page 101- 120. Clauses 9.1 – 9.61. Health Impact assessment- Cl 3.186
We (HRA) brought to the authorities’ attention various anomalies in the financial accountability in assessing the “Contributions” without giving considerations to contingency for increases in inflation and time related uplift. HRA are happy to be consulted in the future.
HRA investigated the Health Provision indicated in Section 106 ‘contributions and concentrated on the sum stated to be for the Riverside Medical Centre on Ferry Road and found the sum stated to be inadequate. We fear the same decisions may be made for the foreseeable future. As HRA have been active on this issue it would be in the interests of all parties to consult and agree a course of action.

Section 10 Protecting and Enhancing our Environment.
Page 121 - Clause 10.1 to 10.4
General planning policy of the NPPF suggests minimising vulnerability and provide resilience to climate change impacts. RDC and ECC must provide a course of actions.

Page 121 – 141. Clause 10.5 – 10.72 Green Belt
We agree the purposes of the NPPF clause 10.7-10.8 in that the 5 purposes of the Green Belt set out to:
1. Check the unrestricted sprawl of large built up areas
2. Prevent neighbouring towns merging into one another.
3. Assist in safeguarding the countryside from ‘encroachment.
4. Preserve the setting and special character of historic towns.
5. Assist in urban regeneration, by encouraging the recycling of derelict and other urban land ie Brownfield Sites. Inappropriate development. (Page 122. Clause 10.8) Specifically states that the construction of new buildings in the Green Belt is generally considered to be inappropriate development.
The Hullbridge Residents Association respectively request that Rochford District Council adhere to these policies and review the New Local Plan Document. It may be appropriate to classify this as “Special Measures” and allow the intervention of a Planning Inspector to adjudicate.

Stakeholder Ref: CP15678E Community Representative Ref: 29007

Section 11. Detailed Policy Considerations. Pages 142- 165
Page 142. Clause 11.2 Mix of Affordable Homes

In HRA discussions with a developer we were advised that the RDC stated that the Core Strategy and the Land Development Framework were ‘out of date’ therefore some clauses were not applicable.
The same situation applied to discussions when applied to the Localism Act. The Core Strategy and the NPPF are evident in many statements in this new Local Plan document, so, we consider there has been no change in the above main documents, action is necessary.

Page 155. Clause 11.45 Brownfield Sites. HRA have taken into account clauses 11.45/ 46 and taken into consideration that all Brownfield sites must have priority. NPPF paragraph 89 and Policy DM10 on brownfield development should be an over-riding factor when producing these documents. We refer you to the ‘ambitious’ clauses stipulated in the LDF Management Submission Document- Clause 3 page 33- The Green Belt and Countryside – Vision. Short term. The first paragraph stipulates the “openness and character” of the Rochford Green Belt continues to be protected. Constant reference by our MP Mark Francois has been ignored which places him in an awkward position.

Page 164. Contaminated land. Cl 11.77 to 11.81. Specific example of for
Nevendon Yard Breakers Yard, Lower Road, Hullbridge. Proposed 90 units.
This site is contaminated over a 70 year period and the costs of eradication will be high. The outline application plans are presently delayed for that reason while a historical document is being prepared.

LOCALISM ACT 2011 chapter 20. Item 2.1 (5th bullet point)
The ‘Localism Act’ was brought into force in 2011, the community did not have the opportunity to apply the clauses of this act. This act stipulates that the Local Community has: the ‘right to challenge’ (Part 5, Chapter 2, Clauses 81 to 86).


End of Appeal For Withdrawal.

Dear Sir,
Re: Stakeholder: Reference CP15678E. Community Representative No. 29007.

New Local Plan 2021 Consultation. Issues and Options Documents & Statement of Community Involvement and the Spatial Options documents.

We request Rochford District Council to invite the Government Planning Inspector to find that the New Local Plan 2021 must be withdrawn for reasons mentioned below.
In our consideration the Map A, on the basis of the relevant Legislation Guidance in the National Planning Policy Framework is not:
Positively Prepared
Justified
Effective
Consistent with National Policy

There are sufficient clauses in the NPPF, LDF and Localism Act which stipulate that all issues must be considered including Infrastructure and in areas environmentally threatened as shown in the Environment Agency and the Insurance Company data (Flood maps). It is imperative proper assessments be made in accordance with the NPPF regulations such as Flood, Road Network, Proximity to rivers and all issues set out below. Our experience from the current Malyons Lane large development that our SCI will be ignored again unless we have support from our MP Mark Francois and all the Councillors who are continually proud to state they are Community minded.

The Hullbridge Residents Association have viewed the Local Development Framework Evidence Base and note that the contents are a repeat of the documents issued in 2015 as are the documents mentioned above
Along with the accompanying Integrated Impact Assessment.

Section 1. Introduction
1.1 States this is a review document of the original adoption in 2016, now presented in repetition but revised in 2015 and 2017 (for 2021).

We understand the need for additional homes, but we are concerned that ‘Infrastructure is not given priority as stated by our MP Mark Francois and indeed Government directives, particularly the existing infrastructure but continually being ignored.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

Page 1. Clause 1.2

HRA produced and delivered to RDC a 45-page document on the Core Strategy, Land Development Framework (LDF), National Planning Policy Framework (NPPF) and Localism Act for a development in progress and submitted some 525 issues in the planning documents presented by RDC without a proper response.
The clauses about Community Consultation being important is just a paper exercise to convince the Planning Inspector that the community support all the data produced.

HRA 9 years of experience has shown RDC and Councillors lack of the understanding or interpretation of Community Involvement, proper consultation and transparency, and fear another regretful experience with all sites being put forward for possible development. Having spoken to some Councillors they state that these site will not necessarily be approved to allow planning applications, but past experience does not provide any confidence that the community issues will be taken into account..
We make a plea to the Government Planning Inspector to investigate reasons why the community are ignored in proper consultation.

36 Sites.
We demonstrate our reasons for our rejection of many sites (stated in our document marked “Exhibit B- Issues and Options”) until the subject of the infrastructure (in all aspects- including existing) are reviewed This is an important subject and we extend our Plea to the Planning Inspector to set this review in motion and allow full participation by the Community Representative.

We consider the following clauses of the NPPF and Core Strategy must be applied:

NPFF 3– Core Planning Principles. Pages 1, 5-6, Clauses 1-2, 6-17.
NPPF 4 – Promoting Sustainable Transport.
NPPF 5 – Supporting high quality communications infrastructure. With roads/transport a priority.
NPPF 6 – Delivering a wide choice of high quality homes.
NPPF 7- Requiring Good Design.
NPPF 8 – Promoting Healthy communities.
NPPF 9 - Protecting the Green Belt land.
NPPF 10- Meeting the Challenge of Climate Change, Flooding & Coastal change.
NPPF 11- Conserving and enhancing the future environment.
NPPF Plan Making – Local Plans (p. 37).
NPPF Using a Proportionate evidence base- (p. 38).
NPPF Ensuring Viability and Deliverability- ( p. 41).
NPPF Decision taking – Pre-application engagement & front loading, (p. 45).
Technical Guidance to the NPPF- Flood risk on page 2. Sequential and Exceptional Tests p. 3 to 7.
NPPF - Sequential and Exceptional Tests –

Drainage
Sustainable drainage systems;
We have submitted documents in respect of the existing drainage system needing substantial improvements prior to any links being provided to the new developments and should be part of the necessary required Infrastructure works we have continually highlighted that the present system is not ‘fit for purpose’, but this was ignored. RDC are duty bound to inform ECC (RDC state that this is not their responsibility.


Stakeholder Ref: CP15678E Community Representative Ref: 29007


Page 2.
Clause 1.7 Statement of Community Involvement.
Having been disappointed with the first Statement of Community Involvement document in 2013 and 2016 we take the clause 1.7 on page 2 seriously and look forward to proper ‘consultation’ by RDC, and not use our submission purely as a ‘tick-box’ exercise to prove to the Planning Inspector that the regulations are observed and, our views have been taken into account but we have not seen these issues progressed to amendments in the Local Plan. HRA represent the Hullbridge community and have the right for engagement as stated in the NPPF and the Localism Act.

Clauses 1.8 & 1.9.
A plan indicating 36 additional sites on Map A in Hullbridge along with a further 6 sites not identified on Map A. Please refer to our Exhibit A on pages 14 and 15.

Clause 1.10 is of special interest as it mentions “on-going consultation” at every stage. We did not have the opportunity to discuss ‘The Draft Scoping Report’ which was published on the RDC websites, and the residents, businesses and other ‘stakeholders’ on the RDC mailing list were not consulted (HRA is a Stakeholder and Representative)- continually ignored by RDC- indeed HRA have correspondence relating to this issue that “if we did not like it we should consider litigation’.

Clause 1.14 on page 4 is of special interest to us as we placed emphasis on the Localism Act (2011) with the Managing Director of RDC and were told that the Localism Act was irrelevant. Why is it now more relevant than before? We request this ‘Act’ to be included as it supports Human Rights.

Clause 1.16. Only one ‘drop-in session’ was set up at Hullbridge Community Centre on 24/8/21. The attendance was low, HRA committee had 9 committee members present who asked questions and had responses which do not reflect the issues put forward in this ‘Plea’. One answer took us by surprise, that the Essex Design Guide which we have referred to throughout has been replaced by Rochford own Design Guide. When we consider the reduced staff levels with some unqualified planning staff it leads us to believe that this design guide will be subject to much criticism. We hope the Government Inspector will take this into account.

Planning law requires that “Call for Sites” which falls part of the development plan in accordance with the Regulations Governing Neighbourhood Planning Laws- NPPF 6 - Plans and Strategies – Part 6, Chapter 1, clauses 109 to 113, allows for Neighbourhood Planning – Part 6, chapter 3, clauses 116 to 121., and gives the community the right to Consultation – Part 6, chapter 4, clause 122. We challenge RDC to approve our application for this Neighbourhood Planning Group and a Statutory Consultee status which will also be an asset to the Hullbridge Parish Council. No explanation is given for reasons why we are not allowed to have consultation to give us good reasons why the regulations are not being properly debated and a conclusion found. This attitude denies community skills and professions adequately proven over 9 years of hard work, not acknowledged.

The four principles that follow imply that the core strategy should be relevant, sustainable and ‘Fit for Purpose’ and become part of the NPPF and LDF:
• Positively prepared.
Our observation on the previous Local Plan that insufficient forward planning had been carried in accordance with the Core Strategy which should have been adhered to and we will not be surprised if the same ‘policy’ will prevail. We look forward to the Planning Inspector requesting a coordinated approach and consultation with the community representatives, as the present system is not fit for purpose.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

• Justified.
In view of the aforesaid we do not believe there was any justification to allow more sites to be put forward without clear thinking on assessments being made in respect of the “existing Infrastructure”, and the use of Green Belt land being used instead of Brownfield land and the other issues stated in this document.
The Core Strategy, NPPF and LDF and Localism Act all express that Green Belt land should only be used as a last resort and only under exceptional circumstances, many issues which we have demonstrated have not been addressed sufficiently. Can RDC demonstrate why they are unable to adhere to the rules and regulations designed to safeguard the community.
According to the Localism Act 2011, we have demonstrated that transparency and consultation were lacking with the community. This has to be rectified and included within the proposed Local Plan.
• Effective
The conditions for the development of the 36 Hullbridge sites will not be satisfied for the reasons given above, therefore we consider a complete review of these possible proposed developments and the Core Strategy allows for the community to raise these issues and get into meaningful dialogue with RDC.
• Consistent with National Policy
National policy insists that all the policies stated should be transparent, proper consultation pursued in relations to all the development criteria. We do not believe that proper feasibility studies, risk analysis have been conducted in order to satisfy the requirements of the NPPF and LDF. Most subjects referred to in this presentation will imply reasons for withdrawal, in view of Government directives and regulations listed above.
The Localism Act 2011 Chapter 20. suggested meaningful dialogue with the HRA. Our residents asked what guarantees will be given to HRA that we will be listened to, not merely placing this document on RDC website to satisfy the Planning Inspector requirements. We require RDC Planning/Legal department to clarify.

Clauses 1.18 and 1.19 speaks of ‘community-led planning’ which is of interest to HRA but all our applications and requests for clarification are ignored. We have consistently placed great emphasis on ‘community cohesion’. Which makes for good public awareness. We can produce correspondence to the Parish Council for cohesion in respect to the whole community and help to remove the divisions which exist at present.
HRA have requested support from the Hullbridge Parish Council and indeed our rights should be upheld in accordance with the Localism Act..

Page 5.
Clauses 1.20 and 1.21
How can the RDC ensure that our proposals can be supported for the benefit of the community.
Clause 1.21 Infrastructure Delivery Plan (IDP) and the Community Infrastructure Levy (CIL) will be prepared to set out the circumstances that the CIL will be applied and the key infrastructure that the CIL will seek to fund. The Council will seek to fund this through a ‘Community levy’. This implies that the RDC are not protecting the community. ECC financial planning administration needs reviewing on the subject of ‘contingencies’ which should apply to all categories of infrastructure and other important categories to allow for future planning, maintenance and improvement.

The Essex County Council document “Greater Essex Growth” states that Greater Essex Growth and Infrastructure Framework 2016 is not listed or discussed. The Executive Summary says that Section 106 and ‘Community Infrastructure Levy’ (CIL) will fall way short of expectations and other Government Funding will be in ‘shortfall’ to the tune of £ Billions (report produced by AECOM) who also produced the RDC “Sustainability Analysis”, please explain why they did not cite this issue.
Stakeholder Ref: CP15678E Community Representative Ref: 29007

HRA study of funding under section 106, particularly to fund the local Clinics (£164k recently) which was put to the NHS and RDC fell short of the required sum in view of the increased population. HRA requested consultation to allow co-ordinated conclusions. No surprise this was ignored by all concerned.
The normal LA practices are that a 10 year plan allowing the income to be divided into categories of funding allowing for contingencies for each element of Infrastructure to satisfy needs as they arise, so the question is what have you done with those budgets, as we keep being informed of shortage of funds, perhaps the auditors are allowed to explain how that money was spent. We ask, under ‘The Freedom of Information Act’ why the Hullbridge infrastructure was allowed to deteriorate over at least 50 years.
HRA object to the IDP and CIL because these should be RDC, ECC and Agency obligations to use the contingency funds and not produce more rules which allow the LA to cover up their own accountability inadequacies and should not be an ‘extra’ burden to the community.
If approved, this will set a precedent for other forms of funding from the communities. The community are concerned by this new statement lacking in the Core Strategy and the Land Development Framework. Can you blame the community for showing concern that LA mismanagement of funds fall to the communities having to make good the shortfall wherever they occur.

Page 9. Item 3.2. 36 Sites additional development Land.
The Land Mass measured and stated in this clause we find is out of date because several hectares have already been built on since 2012 which should have been taken into consideration, thus reducing the Land Mass area. Your review and consultation is necessary and we look forward to open discussions in
accordance with the Localism Act.

Section 3. Please refer to our Exhibit A- Development density comparison on pages 14/15.
The total measure of 36 sites = 124 hectares (approximately) which will provide a capacity of 3720 dwellings at minimum 30 dwellings per hectare. The minimum density of 30/60 dwellings per hectare can provide 3720 to 7440 dwellings.

Boundary Line.
Further examination of the same map A indicates that 30.5% of the land lies in the adjoining Rawreth Parish. Please refer to our Exhibits A and B on pages 14-15 and 16 – 20 consecutively.
The result provides the following information:
In our examination of the New Local Plan Document, we are unable to find any explanation for dealing with this ‘division’. Using our previous submission in relation to the Boundary Line indicated on the Ordnance Survey shown and confirmed by the Local Boundary Commission, our correspondence with Rochford District Council requesting clarification on the Parish Council division and the financial implications, they refused to accept the existence of this Boundary line. At a meeting with the developer, we were informed that RDC will allow Council Tax collected by Hullbridge on behalf of Rawreth Parish. Have RDC made the necessary application to LBC for the necessary changes to the Boundary Line and whether or not Rawreth will be amalgamated with Hullbridge at some future date.
The same principle applies with the Boundary Commission England and the National Planning Policy Framework regulations, again we ask for specific dialogue to satisfy the regulations. One of the Green Belt policy purpose is to prevent neighbouring towns/villages from merging into one, Can RDC explain why they seem to have abandoned this policy.

Page 10. Clauses 3.6 to 3.8, Figures 2 and 3. “Travel to work outflows and inflows”.
The travel patterns have changed since 2011 by about 18% with the increase of population. We request a review of the information being given, affecting transport congestion and lack of proper infrastructure.

Page 11. Clauses 3.9 to 3.12. Employment statistics.
We suggest a review is necessary. What guarantees will the prospective developers give to employ local skills.
Stakeholder Ref: CP15678E Community Representative Ref: 29007

Pages 12 and 13. Our Environment. Clause 3.13
Previous Statements made by the Environment Department, Highways & Water Agencies and the HSE suggesting assessments made in 2011 and 2014 were ‘insufficient’ and all future assessments will also fall short of efficiency with funding being used as an excuse to minimise costs giving rise to lack of obligations to this community and to blame Government pressure to satisfy the development quota being used as an excuse to limit the scale of assessments, thus breaching the clauses in the LDF, NPPF and Localism Act.
The same agencies gave evidence to the Planning Inspector that Hullbridge is a ‘sparsely populated’ area. This can be classified as a false statement knowing that Flood water has been a major concern for many years including surface and foul water discharges onto roads and gardens, due to lack of improved drainage facilities and gardens constantly under water. Further land being put forward for development will exacerbate the infrastructure issue. We are informed that RDC do not keep records of ‘Public health’ issues, any complaints are ignored. Foul sewers are grossly overloaded. A full upgrade of the drainage system has always been overdue. This issue should be investigated rigorously by the RDC and it is their responsibility to inform the ECC.

Page 14. Our Communities.
The Hullbridge population count for 2011 census states a population of 6858. HRA support from the community in 2017 suggests 7000 and in 2019 = 7400.
The current development of 500 homes proves an annual population increase from 2019 to 2023 = 9400 population. The growth in the previous 3 decades (census) indicated an average of 2.2% increase. This indicates an average annual increase of 2% per census. This is contrary to the Core Strategy, LDF and the NPPF and the Localism Act that any increase in population should follow the historical line. Hopes rise for a new climate of close Community Consultation.

Page 15 Table 1. Breakdown of 2011 Population Census.
These possible developments will increase the Hullbridge population (see Exhibit B- Population) to 35,900 which will be close to the present Rayleigh population within 15 to 20 years.

Hullbridge, presently with a ‘village status’ will become a Town with a population probably second only to Rayleigh. The Portfolio Holder (Councillor Ian Ward) stated that the Local Plans have changed and it was now paramount to ‘listen’ and closely ‘consult and engage’ with the community, but most people are sceptical that our voices will be heard, and the necessary amendments put forward by the HRA ‘professionals’ will not be heeded. Hullbridge presently consider all verbal utterances are not considered in favour of the community, and no changes are evident except for many of our issues on planning which HRA had to investigate without any RDC help to satisfy the community q & a meetings.

Clause 3.20 Using HRA figures given above we are unable to reconcile with your statement that “the proportion of residents in all demographic ranges will remain ‘stable’. We advise the RDC to review their information and observe the contents of our Exhibit A and B on pages 14/15 and 16-21 provides the necessary calculation, showing exceptional over-population.

Page 16
Clauses 3.21 to 3.25 needs to be reviewed in respect of the statements made being out of date, as the document is prepared using data prescribed in 2011 without fact-finding surveys being conducted to carry out ‘forward planning’ especially with the owner-occupation criteria becoming financially unreliable. With experience of the Public Finance Initiative (PFI) being suspect it will be necessary to return to Council House Building with participation between Local Government and Housing Associations being a prime ‘home provider’ but all motives are suspect.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

Section 4
Page 17 – Spatial Challenges.
Great emphasis is placed on the laws governing the National Planning Policy Framework. We highlight the following to allow you to respond to the Hullbridge Residents Association.
We request you uphold the clauses requiring Consultation with the community Representative such as the HRA with and allowing replies to issues of importance to the community, before finalising the New Local Plan.

Consultative Objections.
We submit our “Consultative Objections” and conform to the NPPF policy namely – that the Local Authority and the ‘Applicants’ must work closely with those directly affected by their proposals to evolve designs that take account of the views of the community.

Brownfield and Greenfield land.

The allocation DPD Document (Feb 2010)- Discussion & Consultative Document on page 1 states that the Council Statement of Community Involvement is committed to Regulations 25 Public Participation in the preparation of Planning for the District (revised 2017). We ask for the right to be properly consulted on this issue that the allocation document has no brownfield sites identified as given in our Exhibit B.

Section 5.
Page 24. Clause 5.1. Our Vision and Strategic Objectives.
HRA experience gained over 9 years of deliberations over the Hullbridge ‘developments’ and Local Plans, that this has not been a success as the majority of the 185 issues submitted in 2014, not being satisfied, and with alliances formed with other localities the same view is expressed. The fact that you did not respond indicates that we are right on all the issues submitted to you and hope the Planning Inspector will take this into account in respect of all future “Consultation”.
We hope that the Planning Inspector takes into account the atmosphere of distrust by the community.

Clause 5.4 Our current Vision
HRA disagree that what is being prescribed on the Hullbridge Plan will allow the community to have the best quality of life, when there is at least 20 years of disruption to look forward to, which will blight our lives. Whole sale development is taking place with major clauses in the NPPF being disregarded.
A “Considerate Contractor Scheme Notice must be a requirement for all contractors to observe the rules towards the community.

Page 26. Clause 5.10. Rochford District 2037. Our Society
We disagree with the statement made that’ the green infrastructure network across the district has been enhanced to support our population. Many hectares of Green Belt Land are being allowed to be developed disregarding all the clauses which are supposed to protect the Green Belt and Government directives. Articles written by the Campaign to Protect Rural England (CPRE) bear witness to the contrary and the community remain sceptical about the final outcome.
The community believe that the homes will be for the over- burgeoning populace of London, not of Essex. We fail to see how you can demonstrate the indigenous population expansion taking priority.

Page 28. Cl. 5.11. Strategic Objective 13. Flood.
Experience gained by the lack of proper assessments on flood, disregarding all the issues provided to you in 2013. Decisions are being made according to financial constraints.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

RDC now have a recipe for disaster in an area naturally susceptible to surface water discharge from the ‘Rayleigh Heights’ about 65m above ground level and surrounding areas of vulnerable Watery Lane.


Page 29. Strategic Priority 5. Climate change.
The Hullbridge community are concerned that the information provided by various Agencies and Insurance Companies that the 1:100 flood incident is flawed and is more likely to be a maximum 1:25 due to Climate change. There is scepticism that the LA will help change the law and this will be detrimental to the community at large. Sea levels have officially been recorded as rising some 150mm above sea level from the beginning of this century and are forecast to rise by 500mm before the end of this century.

Section 6.
Pages 32 to 38. Clauses 6.8 to 6.29. Tables 2 to 4.
Advance notice. Property Insurance.
The potential Property Insurance costs against ‘flood risk’ and ‘subsidence in these areas, can range from £2500 to £5000. per household depending on the risk analysis.
An exercise on Post Codes SS5 reveals that using the ‘Hawkeye’ system determining the level of associated risks such as flood, subsidence etc., the combined results show that in both instances, subsidence is Red, meaning these are perils which will either be excluded or a large excess applied in respect of subsidence – usually £2,500.00 (£1000.00 being ‘Standard’) and for any areas susceptible to flood, without protection barriers or flood defences will increase the Cost Risk to £5,000.00 per property making ‘flood excess’ a priority and no claims accepted by the Insurance Companies if this is applied to development in flood areas.

Page 38 to 40. Clauses 6.29 to 6.33. Homes for purchase and Affordable Homes.
This document was obviously written before the changes which have taken place in the financial industry and Government policies. The change in ‘affordability’ has not been fully considered. We advise you to review and amend this statement accordingly.
How can you demonstrate the ‘affordability’ during this financial climate, which are likely to continue for the next 10 years, irrespective of the incentives given on stamp duty and directives to the lending institutions? Most younger adults will have great difficulty to purchase homes and maintain mortgage payments.

Table 5 Rochford District- Settlement Hierarchy.
We have always had an issue with the infringement of the Green Belt. Most of the present developments recently completed or under construction are being built on Green Belt land disregarding brownfield sites. We suspect that the new Land Development Framework document questions the need to build on the green belt land. Our Exhibit B presents you with our statements on your LDF

Page 45. Clause 6.48. Housing Density Options .
Earlier we provided calculations for the lowest density of development per hectare, It is evident that the option may be for up to 60 homes per hectare which will increase the incentive provided by the Government and risk the long term harmony in the community and will cause even greater strain and stress on the Hullbridge infrastructure and the community.
RDC must take advantage of requesting funds from the Government announcement of £866m funds from the Housing Infrastructure Fund (HIF) to enable the existing Hullbridge infrastructure be brought up to standard, on the grounds that the previous planning regime’s over the last 30 years have been negligent in dealing with the existing infrastructure as suggested on page 6. Clause 1.21.



Stakeholder Ref: CP15678E Community Representative Ref: 29007


Section 8.
Local Highways Capacity and Infrastructure. Clause 8.3 LDF Development Management Submission Document- Section 5- Transport page 73. Improvements to local road network
The only access points to get to Hullbridge is Lower Road and Hullbridge Road. Watery lane should not be considered as a main thoroughfare and we despair that the Essex County Council, Rochford District Council and the Agencies seem to ignore this fact. We want the Planning Inspector to review his statement in the ‘Planning approval’ given in 2014 that RDC consult with HRA on the feasibility for improvement of this Lane, as it is not ‘fit for purpose’.

Highways Risk Analysis.
HRA are concerned that a proper Highways Risk Analysis has not been carried out by the Core Strategy, NPPF and LDF documents. Further consideration must be given for ‘transparency’ as stated in The Localism Act (2011). Recent replacement of 50 years old Gas services emphasises the disruption which
will be caused by both existing and future construction work. County and Local Authorities please take note.

Watery Lane, is in urgent need of improvement and HRA have corresponded with RDC, ECC and all the Agencies showing Watery Lane and Hullbridge Road are identified as traffic congestion points, in clauses 8.13 to 8.15.
We request that RDC/ECC/Agencies contact the SAT NAV services to remove Watery Lane as a general thoroughfare and emphasise this is “weight restricted” and ‘width restrictive’ and speed limits reviewed with adequate signage..
This lane is too narrow for any vehicles over 30 cwt. The lane is without a public footpath making this lane a health and safety issue which needs urgent rectification. HRA suggest that this section of the document should be reviewed, particularly as the Planning Inspector acknowledged HRA argument that Watery Lane is not ‘fit for purpose’, we reject the statement that Watery Lane is NOT part of the “Strategic Highways Network” please review, amend and highlight for the Planning Inspector to view..

Accessibility to Services. Hullbridge has many un-adopted, single lane and unmade roads making access difficult for the Fire, Police, Refuse, Ambulance and general delivery services and will not be suitable for constant construction site traffic for next 20 years a covenant should be inserted to allow the ECC and their Agencies to make urgent contingencies before the matter gets worse as expansion proceeds..

Fire Hydrants. Hullbridge only has 8 Fire Hydrants to serve the whole village, which is considered inadequate for the fire services.


Page 85 - 90. Clause 8.22 to 8.37. Sustainable Travel.
The transport system is being overhauled to reduce the number of buses serving the communities and the frequency, if this carries on, there will be future major problems. Please refer to LDF Allocations Submission Document Page 60 Cl 3.177/178.

Page 87. Clause 8.31 Rayleigh Air Quality.
Reading this clause we are not confident that something will be done to provide good quality air. It was reported in the media, that dangerous levels of nitrous oxide caused by diesel fumes are being recorded in and around the Rayleigh area. Air quality is lacking in both depth and detail which means the RDC ‘evidence base’ on the subject of traffic, is lacking. Please explain your remedy? This pollution has been apparent for many years but ignored. The community now demand action to remedy this issue.

Stakeholder Ref: CP15678E Community Representative Ref: 29007


Page 92 to 96. Clause 8.45 to 8.58. Water and Flood Risk management.
Flood
At times of flood (frequent - 25 times in 5 years), in Watery Lane, has resulted in many accidents, causing ‘gridlock’ to the whole local traffic system in Hullbridge and surrounding areas. Drainage is unable to cope with excess flood water resulting in overflow of excrement and water into roads and gardens and cross-surging foul water and surface water services

Page 96- 98. Clause 8.59 – 8.66. Renewable Energy Generation.
We agree about the ‘renewable energy’ ‘dream’ from all sources and accept there is natural course of events to be taken for the sake of the concerns on Global Environment. It is the political challenges which become the difficult part to address. Perhaps Political will may help.

Page 98-100. Clause 8.67- 8.75. Planning Obligations and Standard Charges.
Local Authorities ignore the observations and pleas made to review and observe the standards laid down by the NPPF, Core Strategy and LDDF to allow ‘proper’ consultation with the community representatives.
The NPPF guidelines on all planning obligations suggest that the 3 tests as set out, must pass:
1 Necessary to make the development acceptable in planning terms.
2 Directly related to the development.
3 Fairly and reasonable related in scale and kind to the development.
The community want an action plan to allow meaningful consultation with the community.

Section 9 Supporting Health, Community and Culture.
Page 101- 120. Clauses 9.1 – 9.61. Health Impact assessment- Cl 3.186
We (HRA) brought to the authorities’ attention various anomalies in the financial accountability in assessing the “Contributions” without giving considerations to contingency for increases in inflation and time related uplift. HRA are happy to be consulted in the future.
HRA investigated the Health Provision indicated in Section 106 ‘contributions and concentrated on the sum stated to be for the Riverside Medical Centre on Ferry Road and found the sum stated to be inadequate. We fear the same decisions may be made for the foreseeable future. As HRA have been active on this issue it would be in the interests of all parties to consult and agree a course of action.

Section 10 Protecting and Enhancing our Environment.
Page 121 - Clause 10.1 to 10.4
General planning policy of the NPPF suggests minimising vulnerability and provide resilience to climate change impacts. RDC and ECC must provide a course of actions.

Page 121 – 141. Clause 10.5 – 10.72 Green Belt
We agree the purposes of the NPPF clause 10.7-10.8 in that the 5 purposes of the Green Belt set out to:
1. Check the unrestricted sprawl of large built up areas
2. Prevent neighbouring towns merging into one another.
3. Assist in safeguarding the countryside from ‘encroachment.
4. Preserve the setting and special character of historic towns.
5. Assist in urban regeneration, by encouraging the recycling of derelict and other urban land ie Brownfield Sites. Inappropriate development. (Page 122. Clause 10.8) Specifically states that the construction of new buildings in the Green Belt is generally considered to be inappropriate development.
The Hullbridge Residents Association respectively request that Rochford District Council adhere to these policies and review the New Local Plan Document. It may be appropriate to classify this as “Special Measures” and allow the intervention of a Planning Inspector to adjudicate.

Stakeholder Ref: CP15678E Community Representative Ref: 29007

Section 11. Detailed Policy Considerations. Pages 142- 165
Page 142. Clause 11.2 Mix of Affordable Homes

In HRA discussions with a developer we were advised that the RDC stated that the Core Strategy and the Land Development Framework were ‘out of date’ therefore some clauses were not applicable.
The same situation applied to discussions when applied to the Localism Act. The Core Strategy and the NPPF are evident in many statements in this new Local Plan document, so, we consider there has been no change in the above main documents, action is necessary.

Page 155. Clause 11.45 Brownfield Sites. HRA have taken into account clauses 11.45/ 46 and taken into consideration that all Brownfield sites must have priority. NPPF paragraph 89 and Policy DM10 on brownfield development should be an over-riding factor when producing these documents. We refer you to the ‘ambitious’ clauses stipulated in the LDF Management Submission Document- Clause 3 page 33- The Green Belt and Countryside – Vision. Short term. The first paragraph stipulates the “openness and character” of the Rochford Green Belt continues to be protected. Constant reference by our MP Mark Francois has been ignored which places him in an awkward position.

Page 164. Contaminated land. Cl 11.77 to 11.81. Specific example of for
Nevendon Yard Breakers Yard, Lower Road, Hullbridge. Proposed 90 units.
This site is contaminated over a 70 year period and the costs of eradication will be high. The outline application plans are presently delayed for that reason while a historical document is being prepared.

LOCALISM ACT 2011 chapter 20. Item 2.1 (5th bullet point)
The ‘Localism Act’ was brought into force in 2011, the community did not have the opportunity to apply the clauses of this act. This act stipulates that the Local Community has: the ‘right to challenge’ (Part 5, Chapter 2, Clauses 81 to 86).


End of Appeal For Withdrawal.

Dear Sir,
Re: Stakeholder: Reference CP15678E. Community Representative No. 29007.

New Local Plan 2021 Consultation. Issues and Options Documents & Statement of Community Involvement and the Spatial Options documents.

We request Rochford District Council to invite the Government Planning Inspector to find that the New Local Plan 2021 must be withdrawn for reasons mentioned below.
In our consideration the Map A, on the basis of the relevant Legislation Guidance in the National Planning Policy Framework is not:
Positively Prepared
Justified
Effective
Consistent with National Policy

There are sufficient clauses in the NPPF, LDF and Localism Act which stipulate that all issues must be considered including Infrastructure and in areas environmentally threatened as shown in the Environment Agency and the Insurance Company data (Flood maps). It is imperative proper assessments be made in accordance with the NPPF regulations such as Flood, Road Network, Proximity to rivers and all issues set out below. Our experience from the current Malyons Lane large development that our SCI will be ignored again unless we have support from our MP Mark Francois and all the Councillors who are continually proud to state they are Community minded.

The Hullbridge Residents Association have viewed the Local Development Framework Evidence Base and note that the contents are a repeat of the documents issued in 2015 as are the documents mentioned above
Along with the accompanying Integrated Impact Assessment.

Section 1. Introduction
1.1 States this is a review document of the original adoption in 2016, now presented in repetition but revised in 2015 and 2017 (for 2021).

We understand the need for additional homes, but we are concerned that ‘Infrastructure is not given priority as stated by our MP Mark Francois and indeed Government directives, particularly the existing infrastructure but continually being ignored.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

Page 1. Clause 1.2

HRA produced and delivered to RDC a 45-page document on the Core Strategy, Land Development Framework (LDF), National Planning Policy Framework (NPPF) and Localism Act for a development in progress and submitted some 525 issues in the planning documents presented by RDC without a proper response.
The clauses about Community Consultation being important is just a paper exercise to convince the Planning Inspector that the community support all the data produced.

HRA 9 years of experience has shown RDC and Councillors lack of the understanding or interpretation of Community Involvement, proper consultation and transparency, and fear another regretful experience with all sites being put forward for possible development. Having spoken to some Councillors they state that these site will not necessarily be approved to allow planning applications, but past experience does not provide any confidence that the community issues will be taken into account..
We make a plea to the Government Planning Inspector to investigate reasons why the community are ignored in proper consultation.

36 Sites.
We demonstrate our reasons for our rejection of many sites (stated in our document marked “Exhibit B- Issues and Options”) until the subject of the infrastructure (in all aspects- including existing) are reviewed This is an important subject and we extend our Plea to the Planning Inspector to set this review in motion and allow full participation by the Community Representative.

We consider the following clauses of the NPPF and Core Strategy must be applied:

NPFF 3– Core Planning Principles. Pages 1, 5-6, Clauses 1-2, 6-17.
NPPF 4 – Promoting Sustainable Transport.
NPPF 5 – Supporting high quality communications infrastructure. With roads/transport a priority.
NPPF 6 – Delivering a wide choice of high quality homes.
NPPF 7- Requiring Good Design.
NPPF 8 – Promoting Healthy communities.
NPPF 9 - Protecting the Green Belt land.
NPPF 10- Meeting the Challenge of Climate Change, Flooding & Coastal change.
NPPF 11- Conserving and enhancing the future environment.
NPPF Plan Making – Local Plans (p. 37).
NPPF Using a Proportionate evidence base- (p. 38).
NPPF Ensuring Viability and Deliverability- ( p. 41).
NPPF Decision taking – Pre-application engagement & front loading, (p. 45).
Technical Guidance to the NPPF- Flood risk on page 2. Sequential and Exceptional Tests p. 3 to 7.
NPPF - Sequential and Exceptional Tests –

Drainage
Sustainable drainage systems;
We have submitted documents in respect of the existing drainage system needing substantial improvements prior to any links being provided to the new developments and should be part of the necessary required Infrastructure works we have continually highlighted that the present system is not ‘fit for purpose’, but this was ignored. RDC are duty bound to inform ECC (RDC state that this is not their responsibility.


Stakeholder Ref: CP15678E Community Representative Ref: 29007


Page 2.
Clause 1.7 Statement of Community Involvement.
Having been disappointed with the first Statement of Community Involvement document in 2013 and 2016 we take the clause 1.7 on page 2 seriously and look forward to proper ‘consultation’ by RDC, and not use our submission purely as a ‘tick-box’ exercise to prove to the Planning Inspector that the regulations are observed and, our views have been taken into account but we have not seen these issues progressed to amendments in the Local Plan. HRA represent the Hullbridge community and have the right for engagement as stated in the NPPF and the Localism Act.

Clauses 1.8 & 1.9.
A plan indicating 36 additional sites on Map A in Hullbridge along with a further 6 sites not identified on Map A. Please refer to our Exhibit A on pages 14 and 15.

Clause 1.10 is of special interest as it mentions “on-going consultation” at every stage. We did not have the opportunity to discuss ‘The Draft Scoping Report’ which was published on the RDC websites, and the residents, businesses and other ‘stakeholders’ on the RDC mailing list were not consulted (HRA is a Stakeholder and Representative)- continually ignored by RDC- indeed HRA have correspondence relating to this issue that “if we did not like it we should consider litigation’.

Clause 1.14 on page 4 is of special interest to us as we placed emphasis on the Localism Act (2011) with the Managing Director of RDC and were told that the Localism Act was irrelevant. Why is it now more relevant than before? We request this ‘Act’ to be included as it supports Human Rights.

Clause 1.16. Only one ‘drop-in session’ was set up at Hullbridge Community Centre on 24/8/21. The attendance was low, HRA committee had 9 committee members present who asked questions and had responses which do not reflect the issues put forward in this ‘Plea’. One answer took us by surprise, that the Essex Design Guide which we have referred to throughout has been replaced by Rochford own Design Guide. When we consider the reduced staff levels with some unqualified planning staff it leads us to believe that this design guide will be subject to much criticism. We hope the Government Inspector will take this into account.

Planning law requires that “Call for Sites” which falls part of the development plan in accordance with the Regulations Governing Neighbourhood Planning Laws- NPPF 6 - Plans and Strategies – Part 6, Chapter 1, clauses 109 to 113, allows for Neighbourhood Planning – Part 6, chapter 3, clauses 116 to 121., and gives the community the right to Consultation – Part 6, chapter 4, clause 122. We challenge RDC to approve our application for this Neighbourhood Planning Group and a Statutory Consultee status which will also be an asset to the Hullbridge Parish Council. No explanation is given for reasons why we are not allowed to have consultation to give us good reasons why the regulations are not being properly debated and a conclusion found. This attitude denies community skills and professions adequately proven over 9 years of hard work, not acknowledged.

The four principles that follow imply that the core strategy should be relevant, sustainable and ‘Fit for Purpose’ and become part of the NPPF and LDF:
• Positively prepared.
Our observation on the previous Local Plan that insufficient forward planning had been carried in accordance with the Core Strategy which should have been adhered to and we will not be surprised if the same ‘policy’ will prevail. We look forward to the Planning Inspector requesting a coordinated approach and consultation with the community representatives, as the present system is not fit for purpose.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

• Justified.
In view of the aforesaid we do not believe there was any justification to allow more sites to be put forward without clear thinking on assessments being made in respect of the “existing Infrastructure”, and the use of Green Belt land being used instead of Brownfield land and the other issues stated in this document.
The Core Strategy, NPPF and LDF and Localism Act all express that Green Belt land should only be used as a last resort and only under exceptional circumstances, many issues which we have demonstrated have not been addressed sufficiently. Can RDC demonstrate why they are unable to adhere to the rules and regulations designed to safeguard the community.
According to the Localism Act 2011, we have demonstrated that transparency and consultation were lacking with the community. This has to be rectified and included within the proposed Local Plan.
• Effective
The conditions for the development of the 36 Hullbridge sites will not be satisfied for the reasons given above, therefore we consider a complete review of these possible proposed developments and the Core Strategy allows for the community to raise these issues and get into meaningful dialogue with RDC.
• Consistent with National Policy
National policy insists that all the policies stated should be transparent, proper consultation pursued in relations to all the development criteria. We do not believe that proper feasibility studies, risk analysis have been conducted in order to satisfy the requirements of the NPPF and LDF. Most subjects referred to in this presentation will imply reasons for withdrawal, in view of Government directives and regulations listed above.
The Localism Act 2011 Chapter 20. suggested meaningful dialogue with the HRA. Our residents asked what guarantees will be given to HRA that we will be listened to, not merely placing this document on RDC website to satisfy the Planning Inspector requirements. We require RDC Planning/Legal department to clarify.

Clauses 1.18 and 1.19 speaks of ‘community-led planning’ which is of interest to HRA but all our applications and requests for clarification are ignored. We have consistently placed great emphasis on ‘community cohesion’. Which makes for good public awareness. We can produce correspondence to the Parish Council for cohesion in respect to the whole community and help to remove the divisions which exist at present.
HRA have requested support from the Hullbridge Parish Council and indeed our rights should be upheld in accordance with the Localism Act..

Page 5.
Clauses 1.20 and 1.21
How can the RDC ensure that our proposals can be supported for the benefit of the community.
Clause 1.21 Infrastructure Delivery Plan (IDP) and the Community Infrastructure Levy (CIL) will be prepared to set out the circumstances that the CIL will be applied and the key infrastructure that the CIL will seek to fund. The Council will seek to fund this through a ‘Community levy’. This implies that the RDC are not protecting the community. ECC financial planning administration needs reviewing on the subject of ‘contingencies’ which should apply to all categories of infrastructure and other important categories to allow for future planning, maintenance and improvement.

The Essex County Council document “Greater Essex Growth” states that Greater Essex Growth and Infrastructure Framework 2016 is not listed or discussed. The Executive Summary says that Section 106 and ‘Community Infrastructure Levy’ (CIL) will fall way short of expectations and other Government Funding will be in ‘shortfall’ to the tune of £ Billions (report produced by AECOM) who also produced the RDC “Sustainability Analysis”, please explain why they did not cite this issue.
Stakeholder Ref: CP15678E Community Representative Ref: 29007

HRA study of funding under section 106, particularly to fund the local Clinics (£164k recently) which was put to the NHS and RDC fell short of the required sum in view of the increased population. HRA requested consultation to allow co-ordinated conclusions. No surprise this was ignored by all concerned.
The normal LA practices are that a 10 year plan allowing the income to be divided into categories of funding allowing for contingencies for each element of Infrastructure to satisfy needs as they arise, so the question is what have you done with those budgets, as we keep being informed of shortage of funds, perhaps the auditors are allowed to explain how that money was spent. We ask, under ‘The Freedom of Information Act’ why the Hullbridge infrastructure was allowed to deteriorate over at least 50 years.
HRA object to the IDP and CIL because these should be RDC, ECC and Agency obligations to use the contingency funds and not produce more rules which allow the LA to cover up their own accountability inadequacies and should not be an ‘extra’ burden to the community.
If approved, this will set a precedent for other forms of funding from the communities. The community are concerned by this new statement lacking in the Core Strategy and the Land Development Framework. Can you blame the community for showing concern that LA mismanagement of funds fall to the communities having to make good the shortfall wherever they occur.

Page 9. Item 3.2. 36 Sites additional development Land.
The Land Mass measured and stated in this clause we find is out of date because several hectares have already been built on since 2012 which should have been taken into consideration, thus reducing the Land Mass area. Your review and consultation is necessary and we look forward to open discussions in
accordance with the Localism Act.

Section 3. Please refer to our Exhibit A- Development density comparison on pages 14/15.
The total measure of 36 sites = 124 hectares (approximately) which will provide a capacity of 3720 dwellings at minimum 30 dwellings per hectare. The minimum density of 30/60 dwellings per hectare can provide 3720 to 7440 dwellings.

Boundary Line.
Further examination of the same map A indicates that 30.5% of the land lies in the adjoining Rawreth Parish. Please refer to our Exhibits A and B on pages 14-15 and 16 – 20 consecutively.
The result provides the following information:
In our examination of the New Local Plan Document, we are unable to find any explanation for dealing with this ‘division’. Using our previous submission in relation to the Boundary Line indicated on the Ordnance Survey shown and confirmed by the Local Boundary Commission, our correspondence with Rochford District Council requesting clarification on the Parish Council division and the financial implications, they refused to accept the existence of this Boundary line. At a meeting with the developer, we were informed that RDC will allow Council Tax collected by Hullbridge on behalf of Rawreth Parish. Have RDC made the necessary application to LBC for the necessary changes to the Boundary Line and whether or not Rawreth will be amalgamated with Hullbridge at some future date.
The same principle applies with the Boundary Commission England and the National Planning Policy Framework regulations, again we ask for specific dialogue to satisfy the regulations. One of the Green Belt policy purpose is to prevent neighbouring towns/villages from merging into one, Can RDC explain why they seem to have abandoned this policy.

Page 10. Clauses 3.6 to 3.8, Figures 2 and 3. “Travel to work outflows and inflows”.
The travel patterns have changed since 2011 by about 18% with the increase of population. We request a review of the information being given, affecting transport congestion and lack of proper infrastructure.

Page 11. Clauses 3.9 to 3.12. Employment statistics.
We suggest a review is necessary. What guarantees will the prospective developers give to employ local skills.
Stakeholder Ref: CP15678E Community Representative Ref: 29007

Pages 12 and 13. Our Environment. Clause 3.13
Previous Statements made by the Environment Department, Highways & Water Agencies and the HSE suggesting assessments made in 2011 and 2014 were ‘insufficient’ and all future assessments will also fall short of efficiency with funding being used as an excuse to minimise costs giving rise to lack of obligations to this community and to blame Government pressure to satisfy the development quota being used as an excuse to limit the scale of assessments, thus breaching the clauses in the LDF, NPPF and Localism Act.
The same agencies gave evidence to the Planning Inspector that Hullbridge is a ‘sparsely populated’ area. This can be classified as a false statement knowing that Flood water has been a major concern for many years including surface and foul water discharges onto roads and gardens, due to lack of improved drainage facilities and gardens constantly under water. Further land being put forward for development will exacerbate the infrastructure issue. We are informed that RDC do not keep records of ‘Public health’ issues, any complaints are ignored. Foul sewers are grossly overloaded. A full upgrade of the drainage system has always been overdue. This issue should be investigated rigorously by the RDC and it is their responsibility to inform the ECC.

Page 14. Our Communities.
The Hullbridge population count for 2011 census states a population of 6858. HRA support from the community in 2017 suggests 7000 and in 2019 = 7400.
The current development of 500 homes proves an annual population increase from 2019 to 2023 = 9400 population. The growth in the previous 3 decades (census) indicated an average of 2.2% increase. This indicates an average annual increase of 2% per census. This is contrary to the Core Strategy, LDF and the NPPF and the Localism Act that any increase in population should follow the historical line. Hopes rise for a new climate of close Community Consultation.

Page 15 Table 1. Breakdown of 2011 Population Census.
These possible developments will increase the Hullbridge population (see Exhibit B- Population) to 35,900 which will be close to the present Rayleigh population within 15 to 20 years.

Hullbridge, presently with a ‘village status’ will become a Town with a population probably second only to Rayleigh. The Portfolio Holder (Councillor Ian Ward) stated that the Local Plans have changed and it was now paramount to ‘listen’ and closely ‘consult and engage’ with the community, but most people are sceptical that our voices will be heard, and the necessary amendments put forward by the HRA ‘professionals’ will not be heeded. Hullbridge presently consider all verbal utterances are not considered in favour of the community, and no changes are evident except for many of our issues on planning which HRA had to investigate without any RDC help to satisfy the community q & a meetings.

Clause 3.20 Using HRA figures given above we are unable to reconcile with your statement that “the proportion of residents in all demographic ranges will remain ‘stable’. We advise the RDC to review their information and observe the contents of our Exhibit A and B on pages 14/15 and 16-21 provides the necessary calculation, showing exceptional over-population.

Page 16
Clauses 3.21 to 3.25 needs to be reviewed in respect of the statements made being out of date, as the document is prepared using data prescribed in 2011 without fact-finding surveys being conducted to carry out ‘forward planning’ especially with the owner-occupation criteria becoming financially unreliable. With experience of the Public Finance Initiative (PFI) being suspect it will be necessary to return to Council House Building with participation between Local Government and Housing Associations being a prime ‘home provider’ but all motives are suspect.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

Section 4
Page 17 – Spatial Challenges.
Great emphasis is placed on the laws governing the National Planning Policy Framework. We highlight the following to allow you to respond to the Hullbridge Residents Association.
We request you uphold the clauses requiring Consultation with the community Representative such as the HRA with and allowing replies to issues of importance to the community, before finalising the New Local Plan.

Consultative Objections.
We submit our “Consultative Objections” and conform to the NPPF policy namely – that the Local Authority and the ‘Applicants’ must work closely with those directly affected by their proposals to evolve designs that take account of the views of the community.

Brownfield and Greenfield land.

The allocation DPD Document (Feb 2010)- Discussion & Consultative Document on page 1 states that the Council Statement of Community Involvement is committed to Regulations 25 Public Participation in the preparation of Planning for the District (revised 2017). We ask for the right to be properly consulted on this issue that the allocation document has no brownfield sites identified as given in our Exhibit B.

Section 5.
Page 24. Clause 5.1. Our Vision and Strategic Objectives.
HRA experience gained over 9 years of deliberations over the Hullbridge ‘developments’ and Local Plans, that this has not been a success as the majority of the 185 issues submitted in 2014, not being satisfied, and with alliances formed with other localities the same view is expressed. The fact that you did not respond indicates that we are right on all the issues submitted to you and hope the Planning Inspector will take this into account in respect of all future “Consultation”.
We hope that the Planning Inspector takes into account the atmosphere of distrust by the community.

Clause 5.4 Our current Vision
HRA disagree that what is being prescribed on the Hullbridge Plan will allow the community to have the best quality of life, when there is at least 20 years of disruption to look forward to, which will blight our lives. Whole sale development is taking place with major clauses in the NPPF being disregarded.
A “Considerate Contractor Scheme Notice must be a requirement for all contractors to observe the rules towards the community.

Page 26. Clause 5.10. Rochford District 2037. Our Society
We disagree with the statement made that’ the green infrastructure network across the district has been enhanced to support our population. Many hectares of Green Belt Land are being allowed to be developed disregarding all the clauses which are supposed to protect the Green Belt and Government directives. Articles written by the Campaign to Protect Rural England (CPRE) bear witness to the contrary and the community remain sceptical about the final outcome.
The community believe that the homes will be for the over- burgeoning populace of London, not of Essex. We fail to see how you can demonstrate the indigenous population expansion taking priority.

Page 28. Cl. 5.11. Strategic Objective 13. Flood.
Experience gained by the lack of proper assessments on flood, disregarding all the issues provided to you in 2013. Decisions are being made according to financial constraints.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

RDC now have a recipe for disaster in an area naturally susceptible to surface water discharge from the ‘Rayleigh Heights’ about 65m above ground level and surrounding areas of vulnerable Watery Lane.


Page 29. Strategic Priority 5. Climate change.
The Hullbridge community are concerned that the information provided by various Agencies and Insurance Companies that the 1:100 flood incident is flawed and is more likely to be a maximum 1:25 due to Climate change. There is scepticism that the LA will help change the law and this will be detrimental to the community at large. Sea levels have officially been recorded as rising some 150mm above sea level from the beginning of this century and are forecast to rise by 500mm before the end of this century.

Section 6.
Pages 32 to 38. Clauses 6.8 to 6.29. Tables 2 to 4.
Advance notice. Property Insurance.
The potential Property Insurance costs against ‘flood risk’ and ‘subsidence in these areas, can range from £2500 to £5000. per household depending on the risk analysis.
An exercise on Post Codes SS5 reveals that using the ‘Hawkeye’ system determining the level of associated risks such as flood, subsidence etc., the combined results show that in both instances, subsidence is Red, meaning these are perils which will either be excluded or a large excess applied in respect of subsidence – usually £2,500.00 (£1000.00 being ‘Standard’) and for any areas susceptible to flood, without protection barriers or flood defences will increase the Cost Risk to £5,000.00 per property making ‘flood excess’ a priority and no claims accepted by the Insurance Companies if this is applied to development in flood areas.

Page 38 to 40. Clauses 6.29 to 6.33. Homes for purchase and Affordable Homes.
This document was obviously written before the changes which have taken place in the financial industry and Government policies. The change in ‘affordability’ has not been fully considered. We advise you to review and amend this statement accordingly.
How can you demonstrate the ‘affordability’ during this financial climate, which are likely to continue for the next 10 years, irrespective of the incentives given on stamp duty and directives to the lending institutions? Most younger adults will have great difficulty to purchase homes and maintain mortgage payments.

Table 5 Rochford District- Settlement Hierarchy.
We have always had an issue with the infringement of the Green Belt. Most of the present developments recently completed or under construction are being built on Green Belt land disregarding brownfield sites. We suspect that the new Land Development Framework document questions the need to build on the green belt land. Our Exhibit B presents you with our statements on your LDF

Page 45. Clause 6.48. Housing Density Options .
Earlier we provided calculations for the lowest density of development per hectare, It is evident that the option may be for up to 60 homes per hectare which will increase the incentive provided by the Government and risk the long term harmony in the community and will cause even greater strain and stress on the Hullbridge infrastructure and the community.
RDC must take advantage of requesting funds from the Government announcement of £866m funds from the Housing Infrastructure Fund (HIF) to enable the existing Hullbridge infrastructure be brought up to standard, on the grounds that the previous planning regime’s over the last 30 years have been negligent in dealing with the existing infrastructure as suggested on page 6. Clause 1.21.



Stakeholder Ref: CP15678E Community Representative Ref: 29007


Section 8.
Local Highways Capacity and Infrastructure. Clause 8.3 LDF Development Management Submission Document- Section 5- Transport page 73. Improvements to local road network
The only access points to get to Hullbridge is Lower Road and Hullbridge Road. Watery lane should not be considered as a main thoroughfare and we despair that the Essex County Council, Rochford District Council and the Agencies seem to ignore this fact. We want the Planning Inspector to review his statement in the ‘Planning approval’ given in 2014 that RDC consult with HRA on the feasibility for improvement of this Lane, as it is not ‘fit for purpose’.

Highways Risk Analysis.
HRA are concerned that a proper Highways Risk Analysis has not been carried out by the Core Strategy, NPPF and LDF documents. Further consideration must be given for ‘transparency’ as stated in The Localism Act (2011). Recent replacement of 50 years old Gas services emphasises the disruption which
will be caused by both existing and future construction work. County and Local Authorities please take note.

Watery Lane, is in urgent need of improvement and HRA have corresponded with RDC, ECC and all the Agencies showing Watery Lane and Hullbridge Road are identified as traffic congestion points, in clauses 8.13 to 8.15.
We request that RDC/ECC/Agencies contact the SAT NAV services to remove Watery Lane as a general thoroughfare and emphasise this is “weight restricted” and ‘width restrictive’ and speed limits reviewed with adequate signage..
This lane is too narrow for any vehicles over 30 cwt. The lane is without a public footpath making this lane a health and safety issue which needs urgent rectification. HRA suggest that this section of the document should be reviewed, particularly as the Planning Inspector acknowledged HRA argument that Watery Lane is not ‘fit for purpose’, we reject the statement that Watery Lane is NOT part of the “Strategic Highways Network” please review, amend and highlight for the Planning Inspector to view..

Accessibility to Services. Hullbridge has many un-adopted, single lane and unmade roads making access difficult for the Fire, Police, Refuse, Ambulance and general delivery services and will not be suitable for constant construction site traffic for next 20 years a covenant should be inserted to allow the ECC and their Agencies to make urgent contingencies before the matter gets worse as expansion proceeds..

Fire Hydrants. Hullbridge only has 8 Fire Hydrants to serve the whole village, which is considered inadequate for the fire services.


Page 85 - 90. Clause 8.22 to 8.37. Sustainable Travel.
The transport system is being overhauled to reduce the number of buses serving the communities and the frequency, if this carries on, there will be future major problems. Please refer to LDF Allocations Submission Document Page 60 Cl 3.177/178.

Page 87. Clause 8.31 Rayleigh Air Quality.
Reading this clause we are not confident that something will be done to provide good quality air. It was reported in the media, that dangerous levels of nitrous oxide caused by diesel fumes are being recorded in and around the Rayleigh area. Air quality is lacking in both depth and detail which means the RDC ‘evidence base’ on the subject of traffic, is lacking. Please explain your remedy? This pollution has been apparent for many years but ignored. The community now demand action to remedy this issue.

Stakeholder Ref: CP15678E Community Representative Ref: 29007


Page 92 to 96. Clause 8.45 to 8.58. Water and Flood Risk management.
Flood
At times of flood (frequent - 25 times in 5 years), in Watery Lane, has resulted in many accidents, causing ‘gridlock’ to the whole local traffic system in Hullbridge and surrounding areas. Drainage is unable to cope with excess flood water resulting in overflow of excrement and water into roads and gardens and cross-surging foul water and surface water services

Page 96- 98. Clause 8.59 – 8.66. Renewable Energy Generation.
We agree about the ‘renewable energy’ ‘dream’ from all sources and accept there is natural course of events to be taken for the sake of the concerns on Global Environment. It is the political challenges which become the difficult part to address. Perhaps Political will may help.

Page 98-100. Clause 8.67- 8.75. Planning Obligations and Standard Charges.
Local Authorities ignore the observations and pleas made to review and observe the standards laid down by the NPPF, Core Strategy and LDDF to allow ‘proper’ consultation with the community representatives.
The NPPF guidelines on all planning obligations suggest that the 3 tests as set out, must pass:
1 Necessary to make the development acceptable in planning terms.
2 Directly related to the development.
3 Fairly and reasonable related in scale and kind to the development.
The community want an action plan to allow meaningful consultation with the community.

Section 9 Supporting Health, Community and Culture.
Page 101- 120. Clauses 9.1 – 9.61. Health Impact assessment- Cl 3.186
We (HRA) brought to the authorities’ attention various anomalies in the financial accountability in assessing the “Contributions” without giving considerations to contingency for increases in inflation and time related uplift. HRA are happy to be consulted in the future.
HRA investigated the Health Provision indicated in Section 106 ‘contributions and concentrated on the sum stated to be for the Riverside Medical Centre on Ferry Road and found the sum stated to be inadequate. We fear the same decisions may be made for the foreseeable future. As HRA have been active on this issue it would be in the interests of all parties to consult and agree a course of action.

Section 10 Protecting and Enhancing our Environment.
Page 121 - Clause 10.1 to 10.4
General planning policy of the NPPF suggests minimising vulnerability and provide resilience to climate change impacts. RDC and ECC must provide a course of actions.

Page 121 – 141. Clause 10.5 – 10.72 Green Belt
We agree the purposes of the NPPF clause 10.7-10.8 in that the 5 purposes of the Green Belt set out to:
1. Check the unrestricted sprawl of large built up areas
2. Prevent neighbouring towns merging into one another.
3. Assist in safeguarding the countryside from ‘encroachment.
4. Preserve the setting and special character of historic towns.
5. Assist in urban regeneration, by encouraging the recycling of derelict and other urban land ie Brownfield Sites. Inappropriate development. (Page 122. Clause 10.8) Specifically states that the construction of new buildings in the Green Belt is generally considered to be inappropriate development.
The Hullbridge Residents Association respectively request that Rochford District Council adhere to these policies and review the New Local Plan Document. It may be appropriate to classify this as “Special Measures” and allow the intervention of a Planning Inspector to adjudicate.

Stakeholder Ref: CP15678E Community Representative Ref: 29007

Section 11. Detailed Policy Considerations. Pages 142- 165
Page 142. Clause 11.2 Mix of Affordable Homes

In HRA discussions with a developer we were advised that the RDC stated that the Core Strategy and the Land Development Framework were ‘out of date’ therefore some clauses were not applicable.
The same situation applied to discussions when applied to the Localism Act. The Core Strategy and the NPPF are evident in many statements in this new Local Plan document, so, we consider there has been no change in the above main documents, action is necessary.

Page 155. Clause 11.45 Brownfield Sites. HRA have taken into account clauses 11.45/ 46 and taken into consideration that all Brownfield sites must have priority. NPPF paragraph 89 and Policy DM10 on brownfield development should be an over-riding factor when producing these documents. We refer you to the ‘ambitious’ clauses stipulated in the LDF Management Submission Document- Clause 3 page 33- The Green Belt and Countryside – Vision. Short term. The first paragraph stipulates the “openness and character” of the Rochford Green Belt continues to be protected. Constant reference by our MP Mark Francois has been ignored which places him in an awkward position.

Page 164. Contaminated land. Cl 11.77 to 11.81. Specific example of for
Nevendon Yard Breakers Yard, Lower Road, Hullbridge. Proposed 90 units.
This site is contaminated over a 70 year period and the costs of eradication will be high. The outline application plans are presently delayed for that reason while a historical document is being prepared.

LOCALISM ACT 2011 chapter 20. Item 2.1 (5th bullet point)
The ‘Localism Act’ was brought into force in 2011, the community did not have the opportunity to apply the clauses of this act. This act stipulates that the Local Community has: the ‘right to challenge’ (Part 5, Chapter 2, Clauses 81 to 86).


End of Appeal For Withdrawal.

Dear Sir,
Re: Stakeholder: Reference CP15678E. Community Representative No. 29007.

New Local Plan 2021 Consultation. Issues and Options Documents & Statement of Community Involvement and the Spatial Options documents.

We request Rochford District Council to invite the Government Planning Inspector to find that the New Local Plan 2021 must be withdrawn for reasons mentioned below.
In our consideration the Map A, on the basis of the relevant Legislation Guidance in the National Planning Policy Framework is not:
Positively Prepared
Justified
Effective
Consistent with National Policy

There are sufficient clauses in the NPPF, LDF and Localism Act which stipulate that all issues must be considered including Infrastructure and in areas environmentally threatened as shown in the Environment Agency and the Insurance Company data (Flood maps). It is imperative proper assessments be made in accordance with the NPPF regulations such as Flood, Road Network, Proximity to rivers and all issues set out below. Our experience from the current Malyons Lane large development that our SCI will be ignored again unless we have support from our MP Mark Francois and all the Councillors who are continually proud to state they are Community minded.

The Hullbridge Residents Association have viewed the Local Development Framework Evidence Base and note that the contents are a repeat of the documents issued in 2015 as are the documents mentioned above
Along with the accompanying Integrated Impact Assessment.

Section 1. Introduction
1.1 States this is a review document of the original adoption in 2016, now presented in repetition but revised in 2015 and 2017 (for 2021).

We understand the need for additional homes, but we are concerned that ‘Infrastructure is not given priority as stated by our MP Mark Francois and indeed Government directives, particularly the existing infrastructure but continually being ignored.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

Page 1. Clause 1.2

HRA produced and delivered to RDC a 45-page document on the Core Strategy, Land Development Framework (LDF), National Planning Policy Framework (NPPF) and Localism Act for a development in progress and submitted some 525 issues in the planning documents presented by RDC without a proper response.
The clauses about Community Consultation being important is just a paper exercise to convince the Planning Inspector that the community support all the data produced.

HRA 9 years of experience has shown RDC and Councillors lack of the understanding or interpretation of Community Involvement, proper consultation and transparency, and fear another regretful experience with all sites being put forward for possible development. Having spoken to some Councillors they state that these site will not necessarily be approved to allow planning applications, but past experience does not provide any confidence that the community issues will be taken into account..
We make a plea to the Government Planning Inspector to investigate reasons why the community are ignored in proper consultation.

36 Sites.
We demonstrate our reasons for our rejection of many sites (stated in our document marked “Exhibit B- Issues and Options”) until the subject of the infrastructure (in all aspects- including existing) are reviewed This is an important subject and we extend our Plea to the Planning Inspector to set this review in motion and allow full participation by the Community Representative.

We consider the following clauses of the NPPF and Core Strategy must be applied:

NPFF 3– Core Planning Principles. Pages 1, 5-6, Clauses 1-2, 6-17.
NPPF 4 – Promoting Sustainable Transport.
NPPF 5 – Supporting high quality communications infrastructure. With roads/transport a priority.
NPPF 6 – Delivering a wide choice of high quality homes.
NPPF 7- Requiring Good Design.
NPPF 8 – Promoting Healthy communities.
NPPF 9 - Protecting the Green Belt land.
NPPF 10- Meeting the Challenge of Climate Change, Flooding & Coastal change.
NPPF 11- Conserving and enhancing the future environment.
NPPF Plan Making – Local Plans (p. 37).
NPPF Using a Proportionate evidence base- (p. 38).
NPPF Ensuring Viability and Deliverability- ( p. 41).
NPPF Decision taking – Pre-application engagement & front loading, (p. 45).
Technical Guidance to the NPPF- Flood risk on page 2. Sequential and Exceptional Tests p. 3 to 7.
NPPF - Sequential and Exceptional Tests –

Drainage
Sustainable drainage systems;
We have submitted documents in respect of the existing drainage system needing substantial improvements prior to any links being provided to the new developments and should be part of the necessary required Infrastructure works we have continually highlighted that the present system is not ‘fit for purpose’, but this was ignored. RDC are duty bound to inform ECC (RDC state that this is not their responsibility.


Stakeholder Ref: CP15678E Community Representative Ref: 29007


Page 2.
Clause 1.7 Statement of Community Involvement.
Having been disappointed with the first Statement of Community Involvement document in 2013 and 2016 we take the clause 1.7 on page 2 seriously and look forward to proper ‘consultation’ by RDC, and not use our submission purely as a ‘tick-box’ exercise to prove to the Planning Inspector that the regulations are observed and, our views have been taken into account but we have not seen these issues progressed to amendments in the Local Plan. HRA represent the Hullbridge community and have the right for engagement as stated in the NPPF and the Localism Act.

Clauses 1.8 & 1.9.
A plan indicating 36 additional sites on Map A in Hullbridge along with a further 6 sites not identified on Map A. Please refer to our Exhibit A on pages 14 and 15.

Clause 1.10 is of special interest as it mentions “on-going consultation” at every stage. We did not have the opportunity to discuss ‘The Draft Scoping Report’ which was published on the RDC websites, and the residents, businesses and other ‘stakeholders’ on the RDC mailing list were not consulted (HRA is a Stakeholder and Representative)- continually ignored by RDC- indeed HRA have correspondence relating to this issue that “if we did not like it we should consider litigation’.

Clause 1.14 on page 4 is of special interest to us as we placed emphasis on the Localism Act (2011) with the Managing Director of RDC and were told that the Localism Act was irrelevant. Why is it now more relevant than before? We request this ‘Act’ to be included as it supports Human Rights.

Clause 1.16. Only one ‘drop-in session’ was set up at Hullbridge Community Centre on 24/8/21. The attendance was low, HRA committee had 9 committee members present who asked questions and had responses which do not reflect the issues put forward in this ‘Plea’. One answer took us by surprise, that the Essex Design Guide which we have referred to throughout has been replaced by Rochford own Design Guide. When we consider the reduced staff levels with some unqualified planning staff it leads us to believe that this design guide will be subject to much criticism. We hope the Government Inspector will take this into account.

Planning law requires that “Call for Sites” which falls part of the development plan in accordance with the Regulations Governing Neighbourhood Planning Laws- NPPF 6 - Plans and Strategies – Part 6, Chapter 1, clauses 109 to 113, allows for Neighbourhood Planning – Part 6, chapter 3, clauses 116 to 121., and gives the community the right to Consultation – Part 6, chapter 4, clause 122. We challenge RDC to approve our application for this Neighbourhood Planning Group and a Statutory Consultee status which will also be an asset to the Hullbridge Parish Council. No explanation is given for reasons why we are not allowed to have consultation to give us good reasons why the regulations are not being properly debated and a conclusion found. This attitude denies community skills and professions adequately proven over 9 years of hard work, not acknowledged.

The four principles that follow imply that the core strategy should be relevant, sustainable and ‘Fit for Purpose’ and become part of the NPPF and LDF:
• Positively prepared.
Our observation on the previous Local Plan that insufficient forward planning had been carried in accordance with the Core Strategy which should have been adhered to and we will not be surprised if the same ‘policy’ will prevail. We look forward to the Planning Inspector requesting a coordinated approach and consultation with the community representatives, as the present system is not fit for purpose.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

• Justified.
In view of the aforesaid we do not believe there was any justification to allow more sites to be put forward without clear thinking on assessments being made in respect of the “existing Infrastructure”, and the use of Green Belt land being used instead of Brownfield land and the other issues stated in this document.
The Core Strategy, NPPF and LDF and Localism Act all express that Green Belt land should only be used as a last resort and only under exceptional circumstances, many issues which we have demonstrated have not been addressed sufficiently. Can RDC demonstrate why they are unable to adhere to the rules and regulations designed to safeguard the community.
According to the Localism Act 2011, we have demonstrated that transparency and consultation were lacking with the community. This has to be rectified and included within the proposed Local Plan.
• Effective
The conditions for the development of the 36 Hullbridge sites will not be satisfied for the reasons given above, therefore we consider a complete review of these possible proposed developments and the Core Strategy allows for the community to raise these issues and get into meaningful dialogue with RDC.
• Consistent with National Policy
National policy insists that all the policies stated should be transparent, proper consultation pursued in relations to all the development criteria. We do not believe that proper feasibility studies, risk analysis have been conducted in order to satisfy the requirements of the NPPF and LDF. Most subjects referred to in this presentation will imply reasons for withdrawal, in view of Government directives and regulations listed above.
The Localism Act 2011 Chapter 20. suggested meaningful dialogue with the HRA. Our residents asked what guarantees will be given to HRA that we will be listened to, not merely placing this document on RDC website to satisfy the Planning Inspector requirements. We require RDC Planning/Legal department to clarify.

Clauses 1.18 and 1.19 speaks of ‘community-led planning’ which is of interest to HRA but all our applications and requests for clarification are ignored. We have consistently placed great emphasis on ‘community cohesion’. Which makes for good public awareness. We can produce correspondence to the Parish Council for cohesion in respect to the whole community and help to remove the divisions which exist at present.
HRA have requested support from the Hullbridge Parish Council and indeed our rights should be upheld in accordance with the Localism Act..

Page 5.
Clauses 1.20 and 1.21
How can the RDC ensure that our proposals can be supported for the benefit of the community.
Clause 1.21 Infrastructure Delivery Plan (IDP) and the Community Infrastructure Levy (CIL) will be prepared to set out the circumstances that the CIL will be applied and the key infrastructure that the CIL will seek to fund. The Council will seek to fund this through a ‘Community levy’. This implies that the RDC are not protecting the community. ECC financial planning administration needs reviewing on the subject of ‘contingencies’ which should apply to all categories of infrastructure and other important categories to allow for future planning, maintenance and improvement.

The Essex County Council document “Greater Essex Growth” states that Greater Essex Growth and Infrastructure Framework 2016 is not listed or discussed. The Executive Summary says that Section 106 and ‘Community Infrastructure Levy’ (CIL) will fall way short of expectations and other Government Funding will be in ‘shortfall’ to the tune of £ Billions (report produced by AECOM) who also produced the RDC “Sustainability Analysis”, please explain why they did not cite this issue.
Stakeholder Ref: CP15678E Community Representative Ref: 29007

HRA study of funding under section 106, particularly to fund the local Clinics (£164k recently) which was put to the NHS and RDC fell short of the required sum in view of the increased population. HRA requested consultation to allow co-ordinated conclusions. No surprise this was ignored by all concerned.
The normal LA practices are that a 10 year plan allowing the income to be divided into categories of funding allowing for contingencies for each element of Infrastructure to satisfy needs as they arise, so the question is what have you done with those budgets, as we keep being informed of shortage of funds, perhaps the auditors are allowed to explain how that money was spent. We ask, under ‘The Freedom of Information Act’ why the Hullbridge infrastructure was allowed to deteriorate over at least 50 years.
HRA object to the IDP and CIL because these should be RDC, ECC and Agency obligations to use the contingency funds and not produce more rules which allow the LA to cover up their own accountability inadequacies and should not be an ‘extra’ burden to the community.
If approved, this will set a precedent for other forms of funding from the communities. The community are concerned by this new statement lacking in the Core Strategy and the Land Development Framework. Can you blame the community for showing concern that LA mismanagement of funds fall to the communities having to make good the shortfall wherever they occur.

Page 9. Item 3.2. 36 Sites additional development Land.
The Land Mass measured and stated in this clause we find is out of date because several hectares have already been built on since 2012 which should have been taken into consideration, thus reducing the Land Mass area. Your review and consultation is necessary and we look forward to open discussions in
accordance with the Localism Act.

Section 3. Please refer to our Exhibit A- Development density comparison on pages 14/15.
The total measure of 36 sites = 124 hectares (approximately) which will provide a capacity of 3720 dwellings at minimum 30 dwellings per hectare. The minimum density of 30/60 dwellings per hectare can provide 3720 to 7440 dwellings.

Boundary Line.
Further examination of the same map A indicates that 30.5% of the land lies in the adjoining Rawreth Parish. Please refer to our Exhibits A and B on pages 14-15 and 16 – 20 consecutively.
The result provides the following information:
In our examination of the New Local Plan Document, we are unable to find any explanation for dealing with this ‘division’. Using our previous submission in relation to the Boundary Line indicated on the Ordnance Survey shown and confirmed by the Local Boundary Commission, our correspondence with Rochford District Council requesting clarification on the Parish Council division and the financial implications, they refused to accept the existence of this Boundary line. At a meeting with the developer, we were informed that RDC will allow Council Tax collected by Hullbridge on behalf of Rawreth Parish. Have RDC made the necessary application to LBC for the necessary changes to the Boundary Line and whether or not Rawreth will be amalgamated with Hullbridge at some future date.
The same principle applies with the Boundary Commission England and the National Planning Policy Framework regulations, again we ask for specific dialogue to satisfy the regulations. One of the Green Belt policy purpose is to prevent neighbouring towns/villages from merging into one, Can RDC explain why they seem to have abandoned this policy.

Page 10. Clauses 3.6 to 3.8, Figures 2 and 3. “Travel to work outflows and inflows”.
The travel patterns have changed since 2011 by about 18% with the increase of population. We request a review of the information being given, affecting transport congestion and lack of proper infrastructure.

Page 11. Clauses 3.9 to 3.12. Employment statistics.
We suggest a review is necessary. What guarantees will the prospective developers give to employ local skills.
Stakeholder Ref: CP15678E Community Representative Ref: 29007

Pages 12 and 13. Our Environment. Clause 3.13
Previous Statements made by the Environment Department, Highways & Water Agencies and the HSE suggesting assessments made in 2011 and 2014 were ‘insufficient’ and all future assessments will also fall short of efficiency with funding being used as an excuse to minimise costs giving rise to lack of obligations to this community and to blame Government pressure to satisfy the development quota being used as an excuse to limit the scale of assessments, thus breaching the clauses in the LDF, NPPF and Localism Act.
The same agencies gave evidence to the Planning Inspector that Hullbridge is a ‘sparsely populated’ area. This can be classified as a false statement knowing that Flood water has been a major concern for many years including surface and foul water discharges onto roads and gardens, due to lack of improved drainage facilities and gardens constantly under water. Further land being put forward for development will exacerbate the infrastructure issue. We are informed that RDC do not keep records of ‘Public health’ issues, any complaints are ignored. Foul sewers are grossly overloaded. A full upgrade of the drainage system has always been overdue. This issue should be investigated rigorously by the RDC and it is their responsibility to inform the ECC.

Page 14. Our Communities.
The Hullbridge population count for 2011 census states a population of 6858. HRA support from the community in 2017 suggests 7000 and in 2019 = 7400.
The current development of 500 homes proves an annual population increase from 2019 to 2023 = 9400 population. The growth in the previous 3 decades (census) indicated an average of 2.2% increase. This indicates an average annual increase of 2% per census. This is contrary to the Core Strategy, LDF and the NPPF and the Localism Act that any increase in population should follow the historical line. Hopes rise for a new climate of close Community Consultation.

Page 15 Table 1. Breakdown of 2011 Population Census.
These possible developments will increase the Hullbridge population (see Exhibit B- Population) to 35,900 which will be close to the present Rayleigh population within 15 to 20 years.

Hullbridge, presently with a ‘village status’ will become a Town with a population probably second only to Rayleigh. The Portfolio Holder (Councillor Ian Ward) stated that the Local Plans have changed and it was now paramount to ‘listen’ and closely ‘consult and engage’ with the community, but most people are sceptical that our voices will be heard, and the necessary amendments put forward by the HRA ‘professionals’ will not be heeded. Hullbridge presently consider all verbal utterances are not considered in favour of the community, and no changes are evident except for many of our issues on planning which HRA had to investigate without any RDC help to satisfy the community q & a meetings.

Clause 3.20 Using HRA figures given above we are unable to reconcile with your statement that “the proportion of residents in all demographic ranges will remain ‘stable’. We advise the RDC to review their information and observe the contents of our Exhibit A and B on pages 14/15 and 16-21 provides the necessary calculation, showing exceptional over-population.

Page 16
Clauses 3.21 to 3.25 needs to be reviewed in respect of the statements made being out of date, as the document is prepared using data prescribed in 2011 without fact-finding surveys being conducted to carry out ‘forward planning’ especially with the owner-occupation criteria becoming financially unreliable. With experience of the Public Finance Initiative (PFI) being suspect it will be necessary to return to Council House Building with participation between Local Government and Housing Associations being a prime ‘home provider’ but all motives are suspect.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

Section 4
Page 17 – Spatial Challenges.
Great emphasis is placed on the laws governing the National Planning Policy Framework. We highlight the following to allow you to respond to the Hullbridge Residents Association.
We request you uphold the clauses requiring Consultation with the community Representative such as the HRA with and allowing replies to issues of importance to the community, before finalising the New Local Plan.

Consultative Objections.
We submit our “Consultative Objections” and conform to the NPPF policy namely – that the Local Authority and the ‘Applicants’ must work closely with those directly affected by their proposals to evolve designs that take account of the views of the community.

Brownfield and Greenfield land.

The allocation DPD Document (Feb 2010)- Discussion & Consultative Document on page 1 states that the Council Statement of Community Involvement is committed to Regulations 25 Public Participation in the preparation of Planning for the District (revised 2017). We ask for the right to be properly consulted on this issue that the allocation document has no brownfield sites identified as given in our Exhibit B.

Section 5.
Page 24. Clause 5.1. Our Vision and Strategic Objectives.
HRA experience gained over 9 years of deliberations over the Hullbridge ‘developments’ and Local Plans, that this has not been a success as the majority of the 185 issues submitted in 2014, not being satisfied, and with alliances formed with other localities the same view is expressed. The fact that you did not respond indicates that we are right on all the issues submitted to you and hope the Planning Inspector will take this into account in respect of all future “Consultation”.
We hope that the Planning Inspector takes into account the atmosphere of distrust by the community.

Clause 5.4 Our current Vision
HRA disagree that what is being prescribed on the Hullbridge Plan will allow the community to have the best quality of life, when there is at least 20 years of disruption to look forward to, which will blight our lives. Whole sale development is taking place with major clauses in the NPPF being disregarded.
A “Considerate Contractor Scheme Notice must be a requirement for all contractors to observe the rules towards the community.

Page 26. Clause 5.10. Rochford District 2037. Our Society
We disagree with the statement made that’ the green infrastructure network across the district has been enhanced to support our population. Many hectares of Green Belt Land are being allowed to be developed disregarding all the clauses which are supposed to protect the Green Belt and Government directives. Articles written by the Campaign to Protect Rural England (CPRE) bear witness to the contrary and the community remain sceptical about the final outcome.
The community believe that the homes will be for the over- burgeoning populace of London, not of Essex. We fail to see how you can demonstrate the indigenous population expansion taking priority.

Page 28. Cl. 5.11. Strategic Objective 13. Flood.
Experience gained by the lack of proper assessments on flood, disregarding all the issues provided to you in 2013. Decisions are being made according to financial constraints.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

RDC now have a recipe for disaster in an area naturally susceptible to surface water discharge from the ‘Rayleigh Heights’ about 65m above ground level and surrounding areas of vulnerable Watery Lane.


Page 29. Strategic Priority 5. Climate change.
The Hullbridge community are concerned that the information provided by various Agencies and Insurance Companies that the 1:100 flood incident is flawed and is more likely to be a maximum 1:25 due to Climate change. There is scepticism that the LA will help change the law and this will be detrimental to the community at large. Sea levels have officially been recorded as rising some 150mm above sea level from the beginning of this century and are forecast to rise by 500mm before the end of this century.

Section 6.
Pages 32 to 38. Clauses 6.8 to 6.29. Tables 2 to 4.
Advance notice. Property Insurance.
The potential Property Insurance costs against ‘flood risk’ and ‘subsidence in these areas, can range from £2500 to £5000. per household depending on the risk analysis.
An exercise on Post Codes SS5 reveals that using the ‘Hawkeye’ system determining the level of associated risks such as flood, subsidence etc., the combined results show that in both instances, subsidence is Red, meaning these are perils which will either be excluded or a large excess applied in respect of subsidence – usually £2,500.00 (£1000.00 being ‘Standard’) and for any areas susceptible to flood, without protection barriers or flood defences will increase the Cost Risk to £5,000.00 per property making ‘flood excess’ a priority and no claims accepted by the Insurance Companies if this is applied to development in flood areas.

Page 38 to 40. Clauses 6.29 to 6.33. Homes for purchase and Affordable Homes.
This document was obviously written before the changes which have taken place in the financial industry and Government policies. The change in ‘affordability’ has not been fully considered. We advise you to review and amend this statement accordingly.
How can you demonstrate the ‘affordability’ during this financial climate, which are likely to continue for the next 10 years, irrespective of the incentives given on stamp duty and directives to the lending institutions? Most younger adults will have great difficulty to purchase homes and maintain mortgage payments.

Table 5 Rochford District- Settlement Hierarchy.
We have always had an issue with the infringement of the Green Belt. Most of the present developments recently completed or under construction are being built on Green Belt land disregarding brownfield sites. We suspect that the new Land Development Framework document questions the need to build on the green belt land. Our Exhibit B presents you with our statements on your LDF

Page 45. Clause 6.48. Housing Density Options .
Earlier we provided calculations for the lowest density of development per hectare, It is evident that the option may be for up to 60 homes per hectare which will increase the incentive provided by the Government and risk the long term harmony in the community and will cause even greater strain and stress on the Hullbridge infrastructure and the community.
RDC must take advantage of requesting funds from the Government announcement of £866m funds from the Housing Infrastructure Fund (HIF) to enable the existing Hullbridge infrastructure be brought up to standard, on the grounds that the previous planning regime’s over the last 30 years have been negligent in dealing with the existing infrastructure as suggested on page 6. Clause 1.21.



Stakeholder Ref: CP15678E Community Representative Ref: 29007


Section 8.
Local Highways Capacity and Infrastructure. Clause 8.3 LDF Development Management Submission Document- Section 5- Transport page 73. Improvements to local road network
The only access points to get to Hullbridge is Lower Road and Hullbridge Road. Watery lane should not be considered as a main thoroughfare and we despair that the Essex County Council, Rochford District Council and the Agencies seem to ignore this fact. We want the Planning Inspector to review his statement in the ‘Planning approval’ given in 2014 that RDC consult with HRA on the feasibility for improvement of this Lane, as it is not ‘fit for purpose’.

Highways Risk Analysis.
HRA are concerned that a proper Highways Risk Analysis has not been carried out by the Core Strategy, NPPF and LDF documents. Further consideration must be given for ‘transparency’ as stated in The Localism Act (2011). Recent replacement of 50 years old Gas services emphasises the disruption which
will be caused by both existing and future construction work. County and Local Authorities please take note.

Watery Lane, is in urgent need of improvement and HRA have corresponded with RDC, ECC and all the Agencies showing Watery Lane and Hullbridge Road are identified as traffic congestion points, in clauses 8.13 to 8.15.
We request that RDC/ECC/Agencies contact the SAT NAV services to remove Watery Lane as a general thoroughfare and emphasise this is “weight restricted” and ‘width restrictive’ and speed limits reviewed with adequate signage..
This lane is too narrow for any vehicles over 30 cwt. The lane is without a public footpath making this lane a health and safety issue which needs urgent rectification. HRA suggest that this section of the document should be reviewed, particularly as the Planning Inspector acknowledged HRA argument that Watery Lane is not ‘fit for purpose’, we reject the statement that Watery Lane is NOT part of the “Strategic Highways Network” please review, amend and highlight for the Planning Inspector to view..

Accessibility to Services. Hullbridge has many un-adopted, single lane and unmade roads making access difficult for the Fire, Police, Refuse, Ambulance and general delivery services and will not be suitable for constant construction site traffic for next 20 years a covenant should be inserted to allow the ECC and their Agencies to make urgent contingencies before the matter gets worse as expansion proceeds..

Fire Hydrants. Hullbridge only has 8 Fire Hydrants to serve the whole village, which is considered inadequate for the fire services.


Page 85 - 90. Clause 8.22 to 8.37. Sustainable Travel.
The transport system is being overhauled to reduce the number of buses serving the communities and the frequency, if this carries on, there will be future major problems. Please refer to LDF Allocations Submission Document Page 60 Cl 3.177/178.

Page 87. Clause 8.31 Rayleigh Air Quality.
Reading this clause we are not confident that something will be done to provide good quality air. It was reported in the media, that dangerous levels of nitrous oxide caused by diesel fumes are being recorded in and around the Rayleigh area. Air quality is lacking in both depth and detail which means the RDC ‘evidence base’ on the subject of traffic, is lacking. Please explain your remedy? This pollution has been apparent for many years but ignored. The community now demand action to remedy this issue.

Stakeholder Ref: CP15678E Community Representative Ref: 29007


Page 92 to 96. Clause 8.45 to 8.58. Water and Flood Risk management.
Flood
At times of flood (frequent - 25 times in 5 years), in Watery Lane, has resulted in many accidents, causing ‘gridlock’ to the whole local traffic system in Hullbridge and surrounding areas. Drainage is unable to cope with excess flood water resulting in overflow of excrement and water into roads and gardens and cross-surging foul water and surface water services

Page 96- 98. Clause 8.59 – 8.66. Renewable Energy Generation.
We agree about the ‘renewable energy’ ‘dream’ from all sources and accept there is natural course of events to be taken for the sake of the concerns on Global Environment. It is the political challenges which become the difficult part to address. Perhaps Political will may help.

Page 98-100. Clause 8.67- 8.75. Planning Obligations and Standard Charges.
Local Authorities ignore the observations and pleas made to review and observe the standards laid down by the NPPF, Core Strategy and LDDF to allow ‘proper’ consultation with the community representatives.
The NPPF guidelines on all planning obligations suggest that the 3 tests as set out, must pass:
1 Necessary to make the development acceptable in planning terms.
2 Directly related to the development.
3 Fairly and reasonable related in scale and kind to the development.
The community want an action plan to allow meaningful consultation with the community.

Section 9 Supporting Health, Community and Culture.
Page 101- 120. Clauses 9.1 – 9.61. Health Impact assessment- Cl 3.186
We (HRA) brought to the authorities’ attention various anomalies in the financial accountability in assessing the “Contributions” without giving considerations to contingency for increases in inflation and time related uplift. HRA are happy to be consulted in the future.
HRA investigated the Health Provision indicated in Section 106 ‘contributions and concentrated on the sum stated to be for the Riverside Medical Centre on Ferry Road and found the sum stated to be inadequate. We fear the same decisions may be made for the foreseeable future. As HRA have been active on this issue it would be in the interests of all parties to consult and agree a course of action.

Section 10 Protecting and Enhancing our Environment.
Page 121 - Clause 10.1 to 10.4
General planning policy of the NPPF suggests minimising vulnerability and provide resilience to climate change impacts. RDC and ECC must provide a course of actions.

Page 121 – 141. Clause 10.5 – 10.72 Green Belt
We agree the purposes of the NPPF clause 10.7-10.8 in that the 5 purposes of the Green Belt set out to:
1. Check the unrestricted sprawl of large built up areas
2. Prevent neighbouring towns merging into one another.
3. Assist in safeguarding the countryside from ‘encroachment.
4. Preserve the setting and special character of historic towns.
5. Assist in urban regeneration, by encouraging the recycling of derelict and other urban land ie Brownfield Sites. Inappropriate development. (Page 122. Clause 10.8) Specifically states that the construction of new buildings in the Green Belt is generally considered to be inappropriate development.
The Hullbridge Residents Association respectively request that Rochford District Council adhere to these policies and review the New Local Plan Document. It may be appropriate to classify this as “Special Measures” and allow the intervention of a Planning Inspector to adjudicate.

Stakeholder Ref: CP15678E Community Representative Ref: 29007

Section 11. Detailed Policy Considerations. Pages 142- 165
Page 142. Clause 11.2 Mix of Affordable Homes

In HRA discussions with a developer we were advised that the RDC stated that the Core Strategy and the Land Development Framework were ‘out of date’ therefore some clauses were not applicable.
The same situation applied to discussions when applied to the Localism Act. The Core Strategy and the NPPF are evident in many statements in this new Local Plan document, so, we consider there has been no change in the above main documents, action is necessary.

Page 155. Clause 11.45 Brownfield Sites. HRA have taken into account clauses 11.45/ 46 and taken into consideration that all Brownfield sites must have priority. NPPF paragraph 89 and Policy DM10 on brownfield development should be an over-riding factor when producing these documents. We refer you to the ‘ambitious’ clauses stipulated in the LDF Management Submission Document- Clause 3 page 33- The Green Belt and Countryside – Vision. Short term. The first paragraph stipulates the “openness and character” of the Rochford Green Belt continues to be protected. Constant reference by our MP Mark Francois has been ignored which places him in an awkward position.

Page 164. Contaminated land. Cl 11.77 to 11.81. Specific example of for
Nevendon Yard Breakers Yard, Lower Road, Hullbridge. Proposed 90 units.
This site is contaminated over a 70 year period and the costs of eradication will be high. The outline application plans are presently delayed for that reason while a historical document is being prepared.

LOCALISM ACT 2011 chapter 20. Item 2.1 (5th bullet point)
The ‘Localism Act’ was brought into force in 2011, the community did not have the opportunity to apply the clauses of this act. This act stipulates that the Local Community has: the ‘right to challenge’ (Part 5, Chapter 2, Clauses 81 to 86).


End of Appeal For Withdrawal.

Dear Sir,
Re: Stakeholder: Reference CP15678E. Community Representative No. 29007.

New Local Plan 2021 Consultation. Issues and Options Documents & Statement of Community Involvement and the Spatial Options documents.

We request Rochford District Council to invite the Government Planning Inspector to find that the New Local Plan 2021 must be withdrawn for reasons mentioned below.
In our consideration the Map A, on the basis of the relevant Legislation Guidance in the National Planning Policy Framework is not:
Positively Prepared
Justified
Effective
Consistent with National Policy

There are sufficient clauses in the NPPF, LDF and Localism Act which stipulate that all issues must be considered including Infrastructure and in areas environmentally threatened as shown in the Environment Agency and the Insurance Company data (Flood maps). It is imperative proper assessments be made in accordance with the NPPF regulations such as Flood, Road Network, Proximity to rivers and all issues set out below. Our experience from the current Malyons Lane large development that our SCI will be ignored again unless we have support from our MP Mark Francois and all the Councillors who are continually proud to state they are Community minded.

The Hullbridge Residents Association have viewed the Local Development Framework Evidence Base and note that the contents are a repeat of the documents issued in 2015 as are the documents mentioned above
Along with the accompanying Integrated Impact Assessment.

Section 1. Introduction
1.1 States this is a review document of the original adoption in 2016, now presented in repetition but revised in 2015 and 2017 (for 2021).

We understand the need for additional homes, but we are concerned that ‘Infrastructure is not given priority as stated by our MP Mark Francois and indeed Government directives, particularly the existing infrastructure but continually being ignored.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

Page 1. Clause 1.2

HRA produced and delivered to RDC a 45-page document on the Core Strategy, Land Development Framework (LDF), National Planning Policy Framework (NPPF) and Localism Act for a development in progress and submitted some 525 issues in the planning documents presented by RDC without a proper response.
The clauses about Community Consultation being important is just a paper exercise to convince the Planning Inspector that the community support all the data produced.

HRA 9 years of experience has shown RDC and Councillors lack of the understanding or interpretation of Community Involvement, proper consultation and transparency, and fear another regretful experience with all sites being put forward for possible development. Having spoken to some Councillors they state that these site will not necessarily be approved to allow planning applications, but past experience does not provide any confidence that the community issues will be taken into account..
We make a plea to the Government Planning Inspector to investigate reasons why the community are ignored in proper consultation.

36 Sites.
We demonstrate our reasons for our rejection of many sites (stated in our document marked “Exhibit B- Issues and Options”) until the subject of the infrastructure (in all aspects- including existing) are reviewed This is an important subject and we extend our Plea to the Planning Inspector to set this review in motion and allow full participation by the Community Representative.

We consider the following clauses of the NPPF and Core Strategy must be applied:

NPFF 3– Core Planning Principles. Pages 1, 5-6, Clauses 1-2, 6-17.
NPPF 4 – Promoting Sustainable Transport.
NPPF 5 – Supporting high quality communications infrastructure. With roads/transport a priority.
NPPF 6 – Delivering a wide choice of high quality homes.
NPPF 7- Requiring Good Design.
NPPF 8 – Promoting Healthy communities.
NPPF 9 - Protecting the Green Belt land.
NPPF 10- Meeting the Challenge of Climate Change, Flooding & Coastal change.
NPPF 11- Conserving and enhancing the future environment.
NPPF Plan Making – Local Plans (p. 37).
NPPF Using a Proportionate evidence base- (p. 38).
NPPF Ensuring Viability and Deliverability- ( p. 41).
NPPF Decision taking – Pre-application engagement & front loading, (p. 45).
Technical Guidance to the NPPF- Flood risk on page 2. Sequential and Exceptional Tests p. 3 to 7.
NPPF - Sequential and Exceptional Tests –

Drainage
Sustainable drainage systems;
We have submitted documents in respect of the existing drainage system needing substantial improvements prior to any links being provided to the new developments and should be part of the necessary required Infrastructure works we have continually highlighted that the present system is not ‘fit for purpose’, but this was ignored. RDC are duty bound to inform ECC (RDC state that this is not their responsibility.


Stakeholder Ref: CP15678E Community Representative Ref: 29007


Page 2.
Clause 1.7 Statement of Community Involvement.
Having been disappointed with the first Statement of Community Involvement document in 2013 and 2016 we take the clause 1.7 on page 2 seriously and look forward to proper ‘consultation’ by RDC, and not use our submission purely as a ‘tick-box’ exercise to prove to the Planning Inspector that the regulations are observed and, our views have been taken into account but we have not seen these issues progressed to amendments in the Local Plan. HRA represent the Hullbridge community and have the right for engagement as stated in the NPPF and the Localism Act.

Clauses 1.8 & 1.9.
A plan indicating 36 additional sites on Map A in Hullbridge along with a further 6 sites not identified on Map A. Please refer to our Exhibit A on pages 14 and 15.

Clause 1.10 is of special interest as it mentions “on-going consultation” at every stage. We did not have the opportunity to discuss ‘The Draft Scoping Report’ which was published on the RDC websites, and the residents, businesses and other ‘stakeholders’ on the RDC mailing list were not consulted (HRA is a Stakeholder and Representative)- continually ignored by RDC- indeed HRA have correspondence relating to this issue that “if we did not like it we should consider litigation’.

Clause 1.14 on page 4 is of special interest to us as we placed emphasis on the Localism Act (2011) with the Managing Director of RDC and were told that the Localism Act was irrelevant. Why is it now more relevant than before? We request this ‘Act’ to be included as it supports Human Rights.

Clause 1.16. Only one ‘drop-in session’ was set up at Hullbridge Community Centre on 24/8/21. The attendance was low, HRA committee had 9 committee members present who asked questions and had responses which do not reflect the issues put forward in this ‘Plea’. One answer took us by surprise, that the Essex Design Guide which we have referred to throughout has been replaced by Rochford own Design Guide. When we consider the reduced staff levels with some unqualified planning staff it leads us to believe that this design guide will be subject to much criticism. We hope the Government Inspector will take this into account.

Planning law requires that “Call for Sites” which falls part of the development plan in accordance with the Regulations Governing Neighbourhood Planning Laws- NPPF 6 - Plans and Strategies – Part 6, Chapter 1, clauses 109 to 113, allows for Neighbourhood Planning – Part 6, chapter 3, clauses 116 to 121., and gives the community the right to Consultation – Part 6, chapter 4, clause 122. We challenge RDC to approve our application for this Neighbourhood Planning Group and a Statutory Consultee status which will also be an asset to the Hullbridge Parish Council. No explanation is given for reasons why we are not allowed to have consultation to give us good reasons why the regulations are not being properly debated and a conclusion found. This attitude denies community skills and professions adequately proven over 9 years of hard work, not acknowledged.

The four principles that follow imply that the core strategy should be relevant, sustainable and ‘Fit for Purpose’ and become part of the NPPF and LDF:
• Positively prepared.
Our observation on the previous Local Plan that insufficient forward planning had been carried in accordance with the Core Strategy which should have been adhered to and we will not be surprised if the same ‘policy’ will prevail. We look forward to the Planning Inspector requesting a coordinated approach and consultation with the community representatives, as the present system is not fit for purpose.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

• Justified.
In view of the aforesaid we do not believe there was any justification to allow more sites to be put forward without clear thinking on assessments being made in respect of the “existing Infrastructure”, and the use of Green Belt land being used instead of Brownfield land and the other issues stated in this document.
The Core Strategy, NPPF and LDF and Localism Act all express that Green Belt land should only be used as a last resort and only under exceptional circumstances, many issues which we have demonstrated have not been addressed sufficiently. Can RDC demonstrate why they are unable to adhere to the rules and regulations designed to safeguard the community.
According to the Localism Act 2011, we have demonstrated that transparency and consultation were lacking with the community. This has to be rectified and included within the proposed Local Plan.
• Effective
The conditions for the development of the 36 Hullbridge sites will not be satisfied for the reasons given above, therefore we consider a complete review of these possible proposed developments and the Core Strategy allows for the community to raise these issues and get into meaningful dialogue with RDC.
• Consistent with National Policy
National policy insists that all the policies stated should be transparent, proper consultation pursued in relations to all the development criteria. We do not believe that proper feasibility studies, risk analysis have been conducted in order to satisfy the requirements of the NPPF and LDF. Most subjects referred to in this presentation will imply reasons for withdrawal, in view of Government directives and regulations listed above.
The Localism Act 2011 Chapter 20. suggested meaningful dialogue with the HRA. Our residents asked what guarantees will be given to HRA that we will be listened to, not merely placing this document on RDC website to satisfy the Planning Inspector requirements. We require RDC Planning/Legal department to clarify.

Clauses 1.18 and 1.19 speaks of ‘community-led planning’ which is of interest to HRA but all our applications and requests for clarification are ignored. We have consistently placed great emphasis on ‘community cohesion’. Which makes for good public awareness. We can produce correspondence to the Parish Council for cohesion in respect to the whole community and help to remove the divisions which exist at present.
HRA have requested support from the Hullbridge Parish Council and indeed our rights should be upheld in accordance with the Localism Act..

Page 5.
Clauses 1.20 and 1.21
How can the RDC ensure that our proposals can be supported for the benefit of the community.
Clause 1.21 Infrastructure Delivery Plan (IDP) and the Community Infrastructure Levy (CIL) will be prepared to set out the circumstances that the CIL will be applied and the key infrastructure that the CIL will seek to fund. The Council will seek to fund this through a ‘Community levy’. This implies that the RDC are not protecting the community. ECC financial planning administration needs reviewing on the subject of ‘contingencies’ which should apply to all categories of infrastructure and other important categories to allow for future planning, maintenance and improvement.

The Essex County Council document “Greater Essex Growth” states that Greater Essex Growth and Infrastructure Framework 2016 is not listed or discussed. The Executive Summary says that Section 106 and ‘Community Infrastructure Levy’ (CIL) will fall way short of expectations and other Government Funding will be in ‘shortfall’ to the tune of £ Billions (report produced by AECOM) who also produced the RDC “Sustainability Analysis”, please explain why they did not cite this issue.
Stakeholder Ref: CP15678E Community Representative Ref: 29007

HRA study of funding under section 106, particularly to fund the local Clinics (£164k recently) which was put to the NHS and RDC fell short of the required sum in view of the increased population. HRA requested consultation to allow co-ordinated conclusions. No surprise this was ignored by all concerned.
The normal LA practices are that a 10 year plan allowing the income to be divided into categories of funding allowing for contingencies for each element of Infrastructure to satisfy needs as they arise, so the question is what have you done with those budgets, as we keep being informed of shortage of funds, perhaps the auditors are allowed to explain how that money was spent. We ask, under ‘The Freedom of Information Act’ why the Hullbridge infrastructure was allowed to deteriorate over at least 50 years.
HRA object to the IDP and CIL because these should be RDC, ECC and Agency obligations to use the contingency funds and not produce more rules which allow the LA to cover up their own accountability inadequacies and should not be an ‘extra’ burden to the community.
If approved, this will set a precedent for other forms of funding from the communities. The community are concerned by this new statement lacking in the Core Strategy and the Land Development Framework. Can you blame the community for showing concern that LA mismanagement of funds fall to the communities having to make good the shortfall wherever they occur.

Page 9. Item 3.2. 36 Sites additional development Land.
The Land Mass measured and stated in this clause we find is out of date because several hectares have already been built on since 2012 which should have been taken into consideration, thus reducing the Land Mass area. Your review and consultation is necessary and we look forward to open discussions in
accordance with the Localism Act.

Section 3. Please refer to our Exhibit A- Development density comparison on pages 14/15.
The total measure of 36 sites = 124 hectares (approximately) which will provide a capacity of 3720 dwellings at minimum 30 dwellings per hectare. The minimum density of 30/60 dwellings per hectare can provide 3720 to 7440 dwellings.

Boundary Line.
Further examination of the same map A indicates that 30.5% of the land lies in the adjoining Rawreth Parish. Please refer to our Exhibits A and B on pages 14-15 and 16 – 20 consecutively.
The result provides the following information:
In our examination of the New Local Plan Document, we are unable to find any explanation for dealing with this ‘division’. Using our previous submission in relation to the Boundary Line indicated on the Ordnance Survey shown and confirmed by the Local Boundary Commission, our correspondence with Rochford District Council requesting clarification on the Parish Council division and the financial implications, they refused to accept the existence of this Boundary line. At a meeting with the developer, we were informed that RDC will allow Council Tax collected by Hullbridge on behalf of Rawreth Parish. Have RDC made the necessary application to LBC for the necessary changes to the Boundary Line and whether or not Rawreth will be amalgamated with Hullbridge at some future date.
The same principle applies with the Boundary Commission England and the National Planning Policy Framework regulations, again we ask for specific dialogue to satisfy the regulations. One of the Green Belt policy purpose is to prevent neighbouring towns/villages from merging into one, Can RDC explain why they seem to have abandoned this policy.

Page 10. Clauses 3.6 to 3.8, Figures 2 and 3. “Travel to work outflows and inflows”.
The travel patterns have changed since 2011 by about 18% with the increase of population. We request a review of the information being given, affecting transport congestion and lack of proper infrastructure.

Page 11. Clauses 3.9 to 3.12. Employment statistics.
We suggest a review is necessary. What guarantees will the prospective developers give to employ local skills.
Stakeholder Ref: CP15678E Community Representative Ref: 29007

Pages 12 and 13. Our Environment. Clause 3.13
Previous Statements made by the Environment Department, Highways & Water Agencies and the HSE suggesting assessments made in 2011 and 2014 were ‘insufficient’ and all future assessments will also fall short of efficiency with funding being used as an excuse to minimise costs giving rise to lack of obligations to this community and to blame Government pressure to satisfy the development quota being used as an excuse to limit the scale of assessments, thus breaching the clauses in the LDF, NPPF and Localism Act.
The same agencies gave evidence to the Planning Inspector that Hullbridge is a ‘sparsely populated’ area. This can be classified as a false statement knowing that Flood water has been a major concern for many years including surface and foul water discharges onto roads and gardens, due to lack of improved drainage facilities and gardens constantly under water. Further land being put forward for development will exacerbate the infrastructure issue. We are informed that RDC do not keep records of ‘Public health’ issues, any complaints are ignored. Foul sewers are grossly overloaded. A full upgrade of the drainage system has always been overdue. This issue should be investigated rigorously by the RDC and it is their responsibility to inform the ECC.

Page 14. Our Communities.
The Hullbridge population count for 2011 census states a population of 6858. HRA support from the community in 2017 suggests 7000 and in 2019 = 7400.
The current development of 500 homes proves an annual population increase from 2019 to 2023 = 9400 population. The growth in the previous 3 decades (census) indicated an average of 2.2% increase. This indicates an average annual increase of 2% per census. This is contrary to the Core Strategy, LDF and the NPPF and the Localism Act that any increase in population should follow the historical line. Hopes rise for a new climate of close Community Consultation.

Page 15 Table 1. Breakdown of 2011 Population Census.
These possible developments will increase the Hullbridge population (see Exhibit B- Population) to 35,900 which will be close to the present Rayleigh population within 15 to 20 years.

Hullbridge, presently with a ‘village status’ will become a Town with a population probably second only to Rayleigh. The Portfolio Holder (Councillor Ian Ward) stated that the Local Plans have changed and it was now paramount to ‘listen’ and closely ‘consult and engage’ with the community, but most people are sceptical that our voices will be heard, and the necessary amendments put forward by the HRA ‘professionals’ will not be heeded. Hullbridge presently consider all verbal utterances are not considered in favour of the community, and no changes are evident except for many of our issues on planning which HRA had to investigate without any RDC help to satisfy the community q & a meetings.

Clause 3.20 Using HRA figures given above we are unable to reconcile with your statement that “the proportion of residents in all demographic ranges will remain ‘stable’. We advise the RDC to review their information and observe the contents of our Exhibit A and B on pages 14/15 and 16-21 provides the necessary calculation, showing exceptional over-population.

Page 16
Clauses 3.21 to 3.25 needs to be reviewed in respect of the statements made being out of date, as the document is prepared using data prescribed in 2011 without fact-finding surveys being conducted to carry out ‘forward planning’ especially with the owner-occupation criteria becoming financially unreliable. With experience of the Public Finance Initiative (PFI) being suspect it will be necessary to return to Council House Building with participation between Local Government and Housing Associations being a prime ‘home provider’ but all motives are suspect.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

Section 4
Page 17 – Spatial Challenges.
Great emphasis is placed on the laws governing the National Planning Policy Framework. We highlight the following to allow you to respond to the Hullbridge Residents Association.
We request you uphold the clauses requiring Consultation with the community Representative such as the HRA with and allowing replies to issues of importance to the community, before finalising the New Local Plan.

Consultative Objections.
We submit our “Consultative Objections” and conform to the NPPF policy namely – that the Local Authority and the ‘Applicants’ must work closely with those directly affected by their proposals to evolve designs that take account of the views of the community.

Brownfield and Greenfield land.

The allocation DPD Document (Feb 2010)- Discussion & Consultative Document on page 1 states that the Council Statement of Community Involvement is committed to Regulations 25 Public Participation in the preparation of Planning for the District (revised 2017). We ask for the right to be properly consulted on this issue that the allocation document has no brownfield sites identified as given in our Exhibit B.

Section 5.
Page 24. Clause 5.1. Our Vision and Strategic Objectives.
HRA experience gained over 9 years of deliberations over the Hullbridge ‘developments’ and Local Plans, that this has not been a success as the majority of the 185 issues submitted in 2014, not being satisfied, and with alliances formed with other localities the same view is expressed. The fact that you did not respond indicates that we are right on all the issues submitted to you and hope the Planning Inspector will take this into account in respect of all future “Consultation”.
We hope that the Planning Inspector takes into account the atmosphere of distrust by the community.

Clause 5.4 Our current Vision
HRA disagree that what is being prescribed on the Hullbridge Plan will allow the community to have the best quality of life, when there is at least 20 years of disruption to look forward to, which will blight our lives. Whole sale development is taking place with major clauses in the NPPF being disregarded.
A “Considerate Contractor Scheme Notice must be a requirement for all contractors to observe the rules towards the community.

Page 26. Clause 5.10. Rochford District 2037. Our Society
We disagree with the statement made that’ the green infrastructure network across the district has been enhanced to support our population. Many hectares of Green Belt Land are being allowed to be developed disregarding all the clauses which are supposed to protect the Green Belt and Government directives. Articles written by the Campaign to Protect Rural England (CPRE) bear witness to the contrary and the community remain sceptical about the final outcome.
The community believe that the homes will be for the over- burgeoning populace of London, not of Essex. We fail to see how you can demonstrate the indigenous population expansion taking priority.

Page 28. Cl. 5.11. Strategic Objective 13. Flood.
Experience gained by the lack of proper assessments on flood, disregarding all the issues provided to you in 2013. Decisions are being made according to financial constraints.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

RDC now have a recipe for disaster in an area naturally susceptible to surface water discharge from the ‘Rayleigh Heights’ about 65m above ground level and surrounding areas of vulnerable Watery Lane.


Page 29. Strategic Priority 5. Climate change.
The Hullbridge community are concerned that the information provided by various Agencies and Insurance Companies that the 1:100 flood incident is flawed and is more likely to be a maximum 1:25 due to Climate change. There is scepticism that the LA will help change the law and this will be detrimental to the community at large. Sea levels have officially been recorded as rising some 150mm above sea level from the beginning of this century and are forecast to rise by 500mm before the end of this century.

Section 6.
Pages 32 to 38. Clauses 6.8 to 6.29. Tables 2 to 4.
Advance notice. Property Insurance.
The potential Property Insurance costs against ‘flood risk’ and ‘subsidence in these areas, can range from £2500 to £5000. per household depending on the risk analysis.
An exercise on Post Codes SS5 reveals that using the ‘Hawkeye’ system determining the level of associated risks such as flood, subsidence etc., the combined results show that in both instances, subsidence is Red, meaning these are perils which will either be excluded or a large excess applied in respect of subsidence – usually £2,500.00 (£1000.00 being ‘Standard’) and for any areas susceptible to flood, without protection barriers or flood defences will increase the Cost Risk to £5,000.00 per property making ‘flood excess’ a priority and no claims accepted by the Insurance Companies if this is applied to development in flood areas.

Page 38 to 40. Clauses 6.29 to 6.33. Homes for purchase and Affordable Homes.
This document was obviously written before the changes which have taken place in the financial industry and Government policies. The change in ‘affordability’ has not been fully considered. We advise you to review and amend this statement accordingly.
How can you demonstrate the ‘affordability’ during this financial climate, which are likely to continue for the next 10 years, irrespective of the incentives given on stamp duty and directives to the lending institutions? Most younger adults will have great difficulty to purchase homes and maintain mortgage payments.

Table 5 Rochford District- Settlement Hierarchy.
We have always had an issue with the infringement of the Green Belt. Most of the present developments recently completed or under construction are being built on Green Belt land disregarding brownfield sites. We suspect that the new Land Development Framework document questions the need to build on the green belt land. Our Exhibit B presents you with our statements on your LDF

Page 45. Clause 6.48. Housing Density Options .
Earlier we provided calculations for the lowest density of development per hectare, It is evident that the option may be for up to 60 homes per hectare which will increase the incentive provided by the Government and risk the long term harmony in the community and will cause even greater strain and stress on the Hullbridge infrastructure and the community.
RDC must take advantage of requesting funds from the Government announcement of £866m funds from the Housing Infrastructure Fund (HIF) to enable the existing Hullbridge infrastructure be brought up to standard, on the grounds that the previous planning regime’s over the last 30 years have been negligent in dealing with the existing infrastructure as suggested on page 6. Clause 1.21.



Stakeholder Ref: CP15678E Community Representative Ref: 29007


Section 8.
Local Highways Capacity and Infrastructure. Clause 8.3 LDF Development Management Submission Document- Section 5- Transport page 73. Improvements to local road network
The only access points to get to Hullbridge is Lower Road and Hullbridge Road. Watery lane should not be considered as a main thoroughfare and we despair that the Essex County Council, Rochford District Council and the Agencies seem to ignore this fact. We want the Planning Inspector to review his statement in the ‘Planning approval’ given in 2014 that RDC consult with HRA on the feasibility for improvement of this Lane, as it is not ‘fit for purpose’.

Highways Risk Analysis.
HRA are concerned that a proper Highways Risk Analysis has not been carried out by the Core Strategy, NPPF and LDF documents. Further consideration must be given for ‘transparency’ as stated in The Localism Act (2011). Recent replacement of 50 years old Gas services emphasises the disruption which
will be caused by both existing and future construction work. County and Local Authorities please take note.

Watery Lane, is in urgent need of improvement and HRA have corresponded with RDC, ECC and all the Agencies showing Watery Lane and Hullbridge Road are identified as traffic congestion points, in clauses 8.13 to 8.15.
We request that RDC/ECC/Agencies contact the SAT NAV services to remove Watery Lane as a general thoroughfare and emphasise this is “weight restricted” and ‘width restrictive’ and speed limits reviewed with adequate signage..
This lane is too narrow for any vehicles over 30 cwt. The lane is without a public footpath making this lane a health and safety issue which needs urgent rectification. HRA suggest that this section of the document should be reviewed, particularly as the Planning Inspector acknowledged HRA argument that Watery Lane is not ‘fit for purpose’, we reject the statement that Watery Lane is NOT part of the “Strategic Highways Network” please review, amend and highlight for the Planning Inspector to view..

Accessibility to Services. Hullbridge has many un-adopted, single lane and unmade roads making access difficult for the Fire, Police, Refuse, Ambulance and general delivery services and will not be suitable for constant construction site traffic for next 20 years a covenant should be inserted to allow the ECC and their Agencies to make urgent contingencies before the matter gets worse as expansion proceeds..

Fire Hydrants. Hullbridge only has 8 Fire Hydrants to serve the whole village, which is considered inadequate for the fire services.


Page 85 - 90. Clause 8.22 to 8.37. Sustainable Travel.
The transport system is being overhauled to reduce the number of buses serving the communities and the frequency, if this carries on, there will be future major problems. Please refer to LDF Allocations Submission Document Page 60 Cl 3.177/178.

Page 87. Clause 8.31 Rayleigh Air Quality.
Reading this clause we are not confident that something will be done to provide good quality air. It was reported in the media, that dangerous levels of nitrous oxide caused by diesel fumes are being recorded in and around the Rayleigh area. Air quality is lacking in both depth and detail which means the RDC ‘evidence base’ on the subject of traffic, is lacking. Please explain your remedy? This pollution has been apparent for many years but ignored. The community now demand action to remedy this issue.

Stakeholder Ref: CP15678E Community Representative Ref: 29007


Page 92 to 96. Clause 8.45 to 8.58. Water and Flood Risk management.
Flood
At times of flood (frequent - 25 times in 5 years), in Watery Lane, has resulted in many accidents, causing ‘gridlock’ to the whole local traffic system in Hullbridge and surrounding areas. Drainage is unable to cope with excess flood water resulting in overflow of excrement and water into roads and gardens and cross-surging foul water and surface water services

Page 96- 98. Clause 8.59 – 8.66. Renewable Energy Generation.
We agree about the ‘renewable energy’ ‘dream’ from all sources and accept there is natural course of events to be taken for the sake of the concerns on Global Environment. It is the political challenges which become the difficult part to address. Perhaps Political will may help.

Page 98-100. Clause 8.67- 8.75. Planning Obligations and Standard Charges.
Local Authorities ignore the observations and pleas made to review and observe the standards laid down by the NPPF, Core Strategy and LDDF to allow ‘proper’ consultation with the community representatives.
The NPPF guidelines on all planning obligations suggest that the 3 tests as set out, must pass:
1 Necessary to make the development acceptable in planning terms.
2 Directly related to the development.
3 Fairly and reasonable related in scale and kind to the development.
The community want an action plan to allow meaningful consultation with the community.

Section 9 Supporting Health, Community and Culture.
Page 101- 120. Clauses 9.1 – 9.61. Health Impact assessment- Cl 3.186
We (HRA) brought to the authorities’ attention various anomalies in the financial accountability in assessing the “Contributions” without giving considerations to contingency for increases in inflation and time related uplift. HRA are happy to be consulted in the future.
HRA investigated the Health Provision indicated in Section 106 ‘contributions and concentrated on the sum stated to be for the Riverside Medical Centre on Ferry Road and found the sum stated to be inadequate. We fear the same decisions may be made for the foreseeable future. As HRA have been active on this issue it would be in the interests of all parties to consult and agree a course of action.

Section 10 Protecting and Enhancing our Environment.
Page 121 - Clause 10.1 to 10.4
General planning policy of the NPPF suggests minimising vulnerability and provide resilience to climate change impacts. RDC and ECC must provide a course of actions.

Page 121 – 141. Clause 10.5 – 10.72 Green Belt
We agree the purposes of the NPPF clause 10.7-10.8 in that the 5 purposes of the Green Belt set out to:
1. Check the unrestricted sprawl of large built up areas
2. Prevent neighbouring towns merging into one another.
3. Assist in safeguarding the countryside from ‘encroachment.
4. Preserve the setting and special character of historic towns.
5. Assist in urban regeneration, by encouraging the recycling of derelict and other urban land ie Brownfield Sites. Inappropriate development. (Page 122. Clause 10.8) Specifically states that the construction of new buildings in the Green Belt is generally considered to be inappropriate development.
The Hullbridge Residents Association respectively request that Rochford District Council adhere to these policies and review the New Local Plan Document. It may be appropriate to classify this as “Special Measures” and allow the intervention of a Planning Inspector to adjudicate.

Stakeholder Ref: CP15678E Community Representative Ref: 29007

Section 11. Detailed Policy Considerations. Pages 142- 165
Page 142. Clause 11.2 Mix of Affordable Homes

In HRA discussions with a developer we were advised that the RDC stated that the Core Strategy and the Land Development Framework were ‘out of date’ therefore some clauses were not applicable.
The same situation applied to discussions when applied to the Localism Act. The Core Strategy and the NPPF are evident in many statements in this new Local Plan document, so, we consider there has been no change in the above main documents, action is necessary.

Page 155. Clause 11.45 Brownfield Sites. HRA have taken into account clauses 11.45/ 46 and taken into consideration that all Brownfield sites must have priority. NPPF paragraph 89 and Policy DM10 on brownfield development should be an over-riding factor when producing these documents. We refer you to the ‘ambitious’ clauses stipulated in the LDF Management Submission Document- Clause 3 page 33- The Green Belt and Countryside – Vision. Short term. The first paragraph stipulates the “openness and character” of the Rochford Green Belt continues to be protected. Constant reference by our MP Mark Francois has been ignored which places him in an awkward position.

Page 164. Contaminated land. Cl 11.77 to 11.81. Specific example of for
Nevendon Yard Breakers Yard, Lower Road, Hullbridge. Proposed 90 units.
This site is contaminated over a 70 year period and the costs of eradication will be high. The outline application plans are presently delayed for that reason while a historical document is being prepared.

LOCALISM ACT 2011 chapter 20. Item 2.1 (5th bullet point)
The ‘Localism Act’ was brought into force in 2011, the community did not have the opportunity to apply the clauses of this act. This act stipulates that the Local Community has: the ‘right to challenge’ (Part 5, Chapter 2, Clauses 81 to 86).


End of Appeal For Withdrawal.

Dear Sir,
Re: Stakeholder: Reference CP15678E. Community Representative No. 29007.

New Local Plan 2021 Consultation. Issues and Options Documents & Statement of Community Involvement and the Spatial Options documents.

We request Rochford District Council to invite the Government Planning Inspector to find that the New Local Plan 2021 must be withdrawn for reasons mentioned below.
In our consideration the Map A, on the basis of the relevant Legislation Guidance in the National Planning Policy Framework is not:
Positively Prepared
Justified
Effective
Consistent with National Policy

There are sufficient clauses in the NPPF, LDF and Localism Act which stipulate that all issues must be considered including Infrastructure and in areas environmentally threatened as shown in the Environment Agency and the Insurance Company data (Flood maps). It is imperative proper assessments be made in accordance with the NPPF regulations such as Flood, Road Network, Proximity to rivers and all issues set out below. Our experience from the current Malyons Lane large development that our SCI will be ignored again unless we have support from our MP Mark Francois and all the Councillors who are continually proud to state they are Community minded.

The Hullbridge Residents Association have viewed the Local Development Framework Evidence Base and note that the contents are a repeat of the documents issued in 2015 as are the documents mentioned above
Along with the accompanying Integrated Impact Assessment.

Section 1. Introduction
1.1 States this is a review document of the original adoption in 2016, now presented in repetition but revised in 2015 and 2017 (for 2021).

We understand the need for additional homes, but we are concerned that ‘Infrastructure is not given priority as stated by our MP Mark Francois and indeed Government directives, particularly the existing infrastructure but continually being ignored.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

Page 1. Clause 1.2

HRA produced and delivered to RDC a 45-page document on the Core Strategy, Land Development Framework (LDF), National Planning Policy Framework (NPPF) and Localism Act for a development in progress and submitted some 525 issues in the planning documents presented by RDC without a proper response.
The clauses about Community Consultation being important is just a paper exercise to convince the Planning Inspector that the community support all the data produced.

HRA 9 years of experience has shown RDC and Councillors lack of the understanding or interpretation of Community Involvement, proper consultation and transparency, and fear another regretful experience with all sites being put forward for possible development. Having spoken to some Councillors they state that these site will not necessarily be approved to allow planning applications, but past experience does not provide any confidence that the community issues will be taken into account..
We make a plea to the Government Planning Inspector to investigate reasons why the community are ignored in proper consultation.

36 Sites.
We demonstrate our reasons for our rejection of many sites (stated in our document marked “Exhibit B- Issues and Options”) until the subject of the infrastructure (in all aspects- including existing) are reviewed This is an important subject and we extend our Plea to the Planning Inspector to set this review in motion and allow full participation by the Community Representative.

We consider the following clauses of the NPPF and Core Strategy must be applied:

NPFF 3– Core Planning Principles. Pages 1, 5-6, Clauses 1-2, 6-17.
NPPF 4 – Promoting Sustainable Transport.
NPPF 5 – Supporting high quality communications infrastructure. With roads/transport a priority.
NPPF 6 – Delivering a wide choice of high quality homes.
NPPF 7- Requiring Good Design.
NPPF 8 – Promoting Healthy communities.
NPPF 9 - Protecting the Green Belt land.
NPPF 10- Meeting the Challenge of Climate Change, Flooding & Coastal change.
NPPF 11- Conserving and enhancing the future environment.
NPPF Plan Making – Local Plans (p. 37).
NPPF Using a Proportionate evidence base- (p. 38).
NPPF Ensuring Viability and Deliverability- ( p. 41).
NPPF Decision taking – Pre-application engagement & front loading, (p. 45).
Technical Guidance to the NPPF- Flood risk on page 2. Sequential and Exceptional Tests p. 3 to 7.
NPPF - Sequential and Exceptional Tests –

Drainage
Sustainable drainage systems;
We have submitted documents in respect of the existing drainage system needing substantial improvements prior to any links being provided to the new developments and should be part of the necessary required Infrastructure works we have continually highlighted that the present system is not ‘fit for purpose’, but this was ignored. RDC are duty bound to inform ECC (RDC state that this is not their responsibility.


Stakeholder Ref: CP15678E Community Representative Ref: 29007


Page 2.
Clause 1.7 Statement of Community Involvement.
Having been disappointed with the first Statement of Community Involvement document in 2013 and 2016 we take the clause 1.7 on page 2 seriously and look forward to proper ‘consultation’ by RDC, and not use our submission purely as a ‘tick-box’ exercise to prove to the Planning Inspector that the regulations are observed and, our views have been taken into account but we have not seen these issues progressed to amendments in the Local Plan. HRA represent the Hullbridge community and have the right for engagement as stated in the NPPF and the Localism Act.

Clauses 1.8 & 1.9.
A plan indicating 36 additional sites on Map A in Hullbridge along with a further 6 sites not identified on Map A. Please refer to our Exhibit A on pages 14 and 15.

Clause 1.10 is of special interest as it mentions “on-going consultation” at every stage. We did not have the opportunity to discuss ‘The Draft Scoping Report’ which was published on the RDC websites, and the residents, businesses and other ‘stakeholders’ on the RDC mailing list were not consulted (HRA is a Stakeholder and Representative)- continually ignored by RDC- indeed HRA have correspondence relating to this issue that “if we did not like it we should consider litigation’.

Clause 1.14 on page 4 is of special interest to us as we placed emphasis on the Localism Act (2011) with the Managing Director of RDC and were told that the Localism Act was irrelevant. Why is it now more relevant than before? We request this ‘Act’ to be included as it supports Human Rights.

Clause 1.16. Only one ‘drop-in session’ was set up at Hullbridge Community Centre on 24/8/21. The attendance was low, HRA committee had 9 committee members present who asked questions and had responses which do not reflect the issues put forward in this ‘Plea’. One answer took us by surprise, that the Essex Design Guide which we have referred to throughout has been replaced by Rochford own Design Guide. When we consider the reduced staff levels with some unqualified planning staff it leads us to believe that this design guide will be subject to much criticism. We hope the Government Inspector will take this into account.

Planning law requires that “Call for Sites” which falls part of the development plan in accordance with the Regulations Governing Neighbourhood Planning Laws- NPPF 6 - Plans and Strategies – Part 6, Chapter 1, clauses 109 to 113, allows for Neighbourhood Planning – Part 6, chapter 3, clauses 116 to 121., and gives the community the right to Consultation – Part 6, chapter 4, clause 122. We challenge RDC to approve our application for this Neighbourhood Planning Group and a Statutory Consultee status which will also be an asset to the Hullbridge Parish Council. No explanation is given for reasons why we are not allowed to have consultation to give us good reasons why the regulations are not being properly debated and a conclusion found. This attitude denies community skills and professions adequately proven over 9 years of hard work, not acknowledged.

The four principles that follow imply that the core strategy should be relevant, sustainable and ‘Fit for Purpose’ and become part of the NPPF and LDF:
• Positively prepared.
Our observation on the previous Local Plan that insufficient forward planning had been carried in accordance with the Core Strategy which should have been adhered to and we will not be surprised if the same ‘policy’ will prevail. We look forward to the Planning Inspector requesting a coordinated approach and consultation with the community representatives, as the present system is not fit for purpose.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

• Justified.
In view of the aforesaid we do not believe there was any justification to allow more sites to be put forward without clear thinking on assessments being made in respect of the “existing Infrastructure”, and the use of Green Belt land being used instead of Brownfield land and the other issues stated in this document.
The Core Strategy, NPPF and LDF and Localism Act all express that Green Belt land should only be used as a last resort and only under exceptional circumstances, many issues which we have demonstrated have not been addressed sufficiently. Can RDC demonstrate why they are unable to adhere to the rules and regulations designed to safeguard the community.
According to the Localism Act 2011, we have demonstrated that transparency and consultation were lacking with the community. This has to be rectified and included within the proposed Local Plan.
• Effective
The conditions for the development of the 36 Hullbridge sites will not be satisfied for the reasons given above, therefore we consider a complete review of these possible proposed developments and the Core Strategy allows for the community to raise these issues and get into meaningful dialogue with RDC.
• Consistent with National Policy
National policy insists that all the policies stated should be transparent, proper consultation pursued in relations to all the development criteria. We do not believe that proper feasibility studies, risk analysis have been conducted in order to satisfy the requirements of the NPPF and LDF. Most subjects referred to in this presentation will imply reasons for withdrawal, in view of Government directives and regulations listed above.
The Localism Act 2011 Chapter 20. suggested meaningful dialogue with the HRA. Our residents asked what guarantees will be given to HRA that we will be listened to, not merely placing this document on RDC website to satisfy the Planning Inspector requirements. We require RDC Planning/Legal department to clarify.

Clauses 1.18 and 1.19 speaks of ‘community-led planning’ which is of interest to HRA but all our applications and requests for clarification are ignored. We have consistently placed great emphasis on ‘community cohesion’. Which makes for good public awareness. We can produce correspondence to the Parish Council for cohesion in respect to the whole community and help to remove the divisions which exist at present.
HRA have requested support from the Hullbridge Parish Council and indeed our rights should be upheld in accordance with the Localism Act..

Page 5.
Clauses 1.20 and 1.21
How can the RDC ensure that our proposals can be supported for the benefit of the community.
Clause 1.21 Infrastructure Delivery Plan (IDP) and the Community Infrastructure Levy (CIL) will be prepared to set out the circumstances that the CIL will be applied and the key infrastructure that the CIL will seek to fund. The Council will seek to fund this through a ‘Community levy’. This implies that the RDC are not protecting the community. ECC financial planning administration needs reviewing on the subject of ‘contingencies’ which should apply to all categories of infrastructure and other important categories to allow for future planning, maintenance and improvement.

The Essex County Council document “Greater Essex Growth” states that Greater Essex Growth and Infrastructure Framework 2016 is not listed or discussed. The Executive Summary says that Section 106 and ‘Community Infrastructure Levy’ (CIL) will fall way short of expectations and other Government Funding will be in ‘shortfall’ to the tune of £ Billions (report produced by AECOM) who also produced the RDC “Sustainability Analysis”, please explain why they did not cite this issue.
Stakeholder Ref: CP15678E Community Representative Ref: 29007

HRA study of funding under section 106, particularly to fund the local Clinics (£164k recently) which was put to the NHS and RDC fell short of the required sum in view of the increased population. HRA requested consultation to allow co-ordinated conclusions. No surprise this was ignored by all concerned.
The normal LA practices are that a 10 year plan allowing the income to be divided into categories of funding allowing for contingencies for each element of Infrastructure to satisfy needs as they arise, so the question is what have you done with those budgets, as we keep being informed of shortage of funds, perhaps the auditors are allowed to explain how that money was spent. We ask, under ‘The Freedom of Information Act’ why the Hullbridge infrastructure was allowed to deteriorate over at least 50 years.
HRA object to the IDP and CIL because these should be RDC, ECC and Agency obligations to use the contingency funds and not produce more rules which allow the LA to cover up their own accountability inadequacies and should not be an ‘extra’ burden to the community.
If approved, this will set a precedent for other forms of funding from the communities. The community are concerned by this new statement lacking in the Core Strategy and the Land Development Framework. Can you blame the community for showing concern that LA mismanagement of funds fall to the communities having to make good the shortfall wherever they occur.

Page 9. Item 3.2. 36 Sites additional development Land.
The Land Mass measured and stated in this clause we find is out of date because several hectares have already been built on since 2012 which should have been taken into consideration, thus reducing the Land Mass area. Your review and consultation is necessary and we look forward to open discussions in
accordance with the Localism Act.

Section 3. Please refer to our Exhibit A- Development density comparison on pages 14/15.
The total measure of 36 sites = 124 hectares (approximately) which will provide a capacity of 3720 dwellings at minimum 30 dwellings per hectare. The minimum density of 30/60 dwellings per hectare can provide 3720 to 7440 dwellings.

Boundary Line.
Further examination of the same map A indicates that 30.5% of the land lies in the adjoining Rawreth Parish. Please refer to our Exhibits A and B on pages 14-15 and 16 – 20 consecutively.
The result provides the following information:
In our examination of the New Local Plan Document, we are unable to find any explanation for dealing with this ‘division’. Using our previous submission in relation to the Boundary Line indicated on the Ordnance Survey shown and confirmed by the Local Boundary Commission, our correspondence with Rochford District Council requesting clarification on the Parish Council division and the financial implications, they refused to accept the existence of this Boundary line. At a meeting with the developer, we were informed that RDC will allow Council Tax collected by Hullbridge on behalf of Rawreth Parish. Have RDC made the necessary application to LBC for the necessary changes to the Boundary Line and whether or not Rawreth will be amalgamated with Hullbridge at some future date.
The same principle applies with the Boundary Commission England and the National Planning Policy Framework regulations, again we ask for specific dialogue to satisfy the regulations. One of the Green Belt policy purpose is to prevent neighbouring towns/villages from merging into one, Can RDC explain why they seem to have abandoned this policy.

Page 10. Clauses 3.6 to 3.8, Figures 2 and 3. “Travel to work outflows and inflows”.
The travel patterns have changed since 2011 by about 18% with the increase of population. We request a review of the information being given, affecting transport congestion and lack of proper infrastructure.

Page 11. Clauses 3.9 to 3.12. Employment statistics.
We suggest a review is necessary. What guarantees will the prospective developers give to employ local skills.
Stakeholder Ref: CP15678E Community Representative Ref: 29007

Pages 12 and 13. Our Environment. Clause 3.13
Previous Statements made by the Environment Department, Highways & Water Agencies and the HSE suggesting assessments made in 2011 and 2014 were ‘insufficient’ and all future assessments will also fall short of efficiency with funding being used as an excuse to minimise costs giving rise to lack of obligations to this community and to blame Government pressure to satisfy the development quota being used as an excuse to limit the scale of assessments, thus breaching the clauses in the LDF, NPPF and Localism Act.
The same agencies gave evidence to the Planning Inspector that Hullbridge is a ‘sparsely populated’ area. This can be classified as a false statement knowing that Flood water has been a major concern for many years including surface and foul water discharges onto roads and gardens, due to lack of improved drainage facilities and gardens constantly under water. Further land being put forward for development will exacerbate the infrastructure issue. We are informed that RDC do not keep records of ‘Public health’ issues, any complaints are ignored. Foul sewers are grossly overloaded. A full upgrade of the drainage system has always been overdue. This issue should be investigated rigorously by the RDC and it is their responsibility to inform the ECC.

Page 14. Our Communities.
The Hullbridge population count for 2011 census states a population of 6858. HRA support from the community in 2017 suggests 7000 and in 2019 = 7400.
The current development of 500 homes proves an annual population increase from 2019 to 2023 = 9400 population. The growth in the previous 3 decades (census) indicated an average of 2.2% increase. This indicates an average annual increase of 2% per census. This is contrary to the Core Strategy, LDF and the NPPF and the Localism Act that any increase in population should follow the historical line. Hopes rise for a new climate of close Community Consultation.

Page 15 Table 1. Breakdown of 2011 Population Census.
These possible developments will increase the Hullbridge population (see Exhibit B- Population) to 35,900 which will be close to the present Rayleigh population within 15 to 20 years.

Hullbridge, presently with a ‘village status’ will become a Town with a population probably second only to Rayleigh. The Portfolio Holder (Councillor Ian Ward) stated that the Local Plans have changed and it was now paramount to ‘listen’ and closely ‘consult and engage’ with the community, but most people are sceptical that our voices will be heard, and the necessary amendments put forward by the HRA ‘professionals’ will not be heeded. Hullbridge presently consider all verbal utterances are not considered in favour of the community, and no changes are evident except for many of our issues on planning which HRA had to investigate without any RDC help to satisfy the community q & a meetings.

Clause 3.20 Using HRA figures given above we are unable to reconcile with your statement that “the proportion of residents in all demographic ranges will remain ‘stable’. We advise the RDC to review their information and observe the contents of our Exhibit A and B on pages 14/15 and 16-21 provides the necessary calculation, showing exceptional over-population.

Page 16
Clauses 3.21 to 3.25 needs to be reviewed in respect of the statements made being out of date, as the document is prepared using data prescribed in 2011 without fact-finding surveys being conducted to carry out ‘forward planning’ especially with the owner-occupation criteria becoming financially unreliable. With experience of the Public Finance Initiative (PFI) being suspect it will be necessary to return to Council House Building with participation between Local Government and Housing Associations being a prime ‘home provider’ but all motives are suspect.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

Section 4
Page 17 – Spatial Challenges.
Great emphasis is placed on the laws governing the National Planning Policy Framework. We highlight the following to allow you to respond to the Hullbridge Residents Association.
We request you uphold the clauses requiring Consultation with the community Representative such as the HRA with and allowing replies to issues of importance to the community, before finalising the New Local Plan.

Consultative Objections.
We submit our “Consultative Objections” and conform to the NPPF policy namely – that the Local Authority and the ‘Applicants’ must work closely with those directly affected by their proposals to evolve designs that take account of the views of the community.

Brownfield and Greenfield land.

The allocation DPD Document (Feb 2010)- Discussion & Consultative Document on page 1 states that the Council Statement of Community Involvement is committed to Regulations 25 Public Participation in the preparation of Planning for the District (revised 2017). We ask for the right to be properly consulted on this issue that the allocation document has no brownfield sites identified as given in our Exhibit B.

Section 5.
Page 24. Clause 5.1. Our Vision and Strategic Objectives.
HRA experience gained over 9 years of deliberations over the Hullbridge ‘developments’ and Local Plans, that this has not been a success as the majority of the 185 issues submitted in 2014, not being satisfied, and with alliances formed with other localities the same view is expressed. The fact that you did not respond indicates that we are right on all the issues submitted to you and hope the Planning Inspector will take this into account in respect of all future “Consultation”.
We hope that the Planning Inspector takes into account the atmosphere of distrust by the community.

Clause 5.4 Our current Vision
HRA disagree that what is being prescribed on the Hullbridge Plan will allow the community to have the best quality of life, when there is at least 20 years of disruption to look forward to, which will blight our lives. Whole sale development is taking place with major clauses in the NPPF being disregarded.
A “Considerate Contractor Scheme Notice must be a requirement for all contractors to observe the rules towards the community.

Page 26. Clause 5.10. Rochford District 2037. Our Society
We disagree with the statement made that’ the green infrastructure network across the district has been enhanced to support our population. Many hectares of Green Belt Land are being allowed to be developed disregarding all the clauses which are supposed to protect the Green Belt and Government directives. Articles written by the Campaign to Protect Rural England (CPRE) bear witness to the contrary and the community remain sceptical about the final outcome.
The community believe that the homes will be for the over- burgeoning populace of London, not of Essex. We fail to see how you can demonstrate the indigenous population expansion taking priority.

Page 28. Cl. 5.11. Strategic Objective 13. Flood.
Experience gained by the lack of proper assessments on flood, disregarding all the issues provided to you in 2013. Decisions are being made according to financial constraints.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

RDC now have a recipe for disaster in an area naturally susceptible to surface water discharge from the ‘Rayleigh Heights’ about 65m above ground level and surrounding areas of vulnerable Watery Lane.


Page 29. Strategic Priority 5. Climate change.
The Hullbridge community are concerned that the information provided by various Agencies and Insurance Companies that the 1:100 flood incident is flawed and is more likely to be a maximum 1:25 due to Climate change. There is scepticism that the LA will help change the law and this will be detrimental to the community at large. Sea levels have officially been recorded as rising some 150mm above sea level from the beginning of this century and are forecast to rise by 500mm before the end of this century.

Section 6.
Pages 32 to 38. Clauses 6.8 to 6.29. Tables 2 to 4.
Advance notice. Property Insurance.
The potential Property Insurance costs against ‘flood risk’ and ‘subsidence in these areas, can range from £2500 to £5000. per household depending on the risk analysis.
An exercise on Post Codes SS5 reveals that using the ‘Hawkeye’ system determining the level of associated risks such as flood, subsidence etc., the combined results show that in both instances, subsidence is Red, meaning these are perils which will either be excluded or a large excess applied in respect of subsidence – usually £2,500.00 (£1000.00 being ‘Standard’) and for any areas susceptible to flood, without protection barriers or flood defences will increase the Cost Risk to £5,000.00 per property making ‘flood excess’ a priority and no claims accepted by the Insurance Companies if this is applied to development in flood areas.

Page 38 to 40. Clauses 6.29 to 6.33. Homes for purchase and Affordable Homes.
This document was obviously written before the changes which have taken place in the financial industry and Government policies. The change in ‘affordability’ has not been fully considered. We advise you to review and amend this statement accordingly.
How can you demonstrate the ‘affordability’ during this financial climate, which are likely to continue for the next 10 years, irrespective of the incentives given on stamp duty and directives to the lending institutions? Most younger adults will have great difficulty to purchase homes and maintain mortgage payments.

Table 5 Rochford District- Settlement Hierarchy.
We have always had an issue with the infringement of the Green Belt. Most of the present developments recently completed or under construction are being built on Green Belt land disregarding brownfield sites. We suspect that the new Land Development Framework document questions the need to build on the green belt land. Our Exhibit B presents you with our statements on your LDF

Page 45. Clause 6.48. Housing Density Options .
Earlier we provided calculations for the lowest density of development per hectare, It is evident that the option may be for up to 60 homes per hectare which will increase the incentive provided by the Government and risk the long term harmony in the community and will cause even greater strain and stress on the Hullbridge infrastructure and the community.
RDC must take advantage of requesting funds from the Government announcement of £866m funds from the Housing Infrastructure Fund (HIF) to enable the existing Hullbridge infrastructure be brought up to standard, on the grounds that the previous planning regime’s over the last 30 years have been negligent in dealing with the existing infrastructure as suggested on page 6. Clause 1.21.



Stakeholder Ref: CP15678E Community Representative Ref: 29007


Section 8.
Local Highways Capacity and Infrastructure. Clause 8.3 LDF Development Management Submission Document- Section 5- Transport page 73. Improvements to local road network
The only access points to get to Hullbridge is Lower Road and Hullbridge Road. Watery lane should not be considered as a main thoroughfare and we despair that the Essex County Council, Rochford District Council and the Agencies seem to ignore this fact. We want the Planning Inspector to review his statement in the ‘Planning approval’ given in 2014 that RDC consult with HRA on the feasibility for improvement of this Lane, as it is not ‘fit for purpose’.

Highways Risk Analysis.
HRA are concerned that a proper Highways Risk Analysis has not been carried out by the Core Strategy, NPPF and LDF documents. Further consideration must be given for ‘transparency’ as stated in The Localism Act (2011). Recent replacement of 50 years old Gas services emphasises the disruption which
will be caused by both existing and future construction work. County and Local Authorities please take note.

Watery Lane, is in urgent need of improvement and HRA have corresponded with RDC, ECC and all the Agencies showing Watery Lane and Hullbridge Road are identified as traffic congestion points, in clauses 8.13 to 8.15.
We request that RDC/ECC/Agencies contact the SAT NAV services to remove Watery Lane as a general thoroughfare and emphasise this is “weight restricted” and ‘width restrictive’ and speed limits reviewed with adequate signage..
This lane is too narrow for any vehicles over 30 cwt. The lane is without a public footpath making this lane a health and safety issue which needs urgent rectification. HRA suggest that this section of the document should be reviewed, particularly as the Planning Inspector acknowledged HRA argument that Watery Lane is not ‘fit for purpose’, we reject the statement that Watery Lane is NOT part of the “Strategic Highways Network” please review, amend and highlight for the Planning Inspector to view..

Accessibility to Services. Hullbridge has many un-adopted, single lane and unmade roads making access difficult for the Fire, Police, Refuse, Ambulance and general delivery services and will not be suitable for constant construction site traffic for next 20 years a covenant should be inserted to allow the ECC and their Agencies to make urgent contingencies before the matter gets worse as expansion proceeds..

Fire Hydrants. Hullbridge only has 8 Fire Hydrants to serve the whole village, which is considered inadequate for the fire services.


Page 85 - 90. Clause 8.22 to 8.37. Sustainable Travel.
The transport system is being overhauled to reduce the number of buses serving the communities and the frequency, if this carries on, there will be future major problems. Please refer to LDF Allocations Submission Document Page 60 Cl 3.177/178.

Page 87. Clause 8.31 Rayleigh Air Quality.
Reading this clause we are not confident that something will be done to provide good quality air. It was reported in the media, that dangerous levels of nitrous oxide caused by diesel fumes are being recorded in and around the Rayleigh area. Air quality is lacking in both depth and detail which means the RDC ‘evidence base’ on the subject of traffic, is lacking. Please explain your remedy? This pollution has been apparent for many years but ignored. The community now demand action to remedy this issue.

Stakeholder Ref: CP15678E Community Representative Ref: 29007


Page 92 to 96. Clause 8.45 to 8.58. Water and Flood Risk management.
Flood
At times of flood (frequent - 25 times in 5 years), in Watery Lane, has resulted in many accidents, causing ‘gridlock’ to the whole local traffic system in Hullbridge and surrounding areas. Drainage is unable to cope with excess flood water resulting in overflow of excrement and water into roads and gardens and cross-surging foul water and surface water services

Page 96- 98. Clause 8.59 – 8.66. Renewable Energy Generation.
We agree about the ‘renewable energy’ ‘dream’ from all sources and accept there is natural course of events to be taken for the sake of the concerns on Global Environment. It is the political challenges which become the difficult part to address. Perhaps Political will may help.

Page 98-100. Clause 8.67- 8.75. Planning Obligations and Standard Charges.
Local Authorities ignore the observations and pleas made to review and observe the standards laid down by the NPPF, Core Strategy and LDDF to allow ‘proper’ consultation with the community representatives.
The NPPF guidelines on all planning obligations suggest that the 3 tests as set out, must pass:
1 Necessary to make the development acceptable in planning terms.
2 Directly related to the development.
3 Fairly and reasonable related in scale and kind to the development.
The community want an action plan to allow meaningful consultation with the community.

Section 9 Supporting Health, Community and Culture.
Page 101- 120. Clauses 9.1 – 9.61. Health Impact assessment- Cl 3.186
We (HRA) brought to the authorities’ attention various anomalies in the financial accountability in assessing the “Contributions” without giving considerations to contingency for increases in inflation and time related uplift. HRA are happy to be consulted in the future.
HRA investigated the Health Provision indicated in Section 106 ‘contributions and concentrated on the sum stated to be for the Riverside Medical Centre on Ferry Road and found the sum stated to be inadequate. We fear the same decisions may be made for the foreseeable future. As HRA have been active on this issue it would be in the interests of all parties to consult and agree a course of action.

Section 10 Protecting and Enhancing our Environment.
Page 121 - Clause 10.1 to 10.4
General planning policy of the NPPF suggests minimising vulnerability and provide resilience to climate change impacts. RDC and ECC must provide a course of actions.

Page 121 – 141. Clause 10.5 – 10.72 Green Belt
We agree the purposes of the NPPF clause 10.7-10.8 in that the 5 purposes of the Green Belt set out to:
1. Check the unrestricted sprawl of large built up areas
2. Prevent neighbouring towns merging into one another.
3. Assist in safeguarding the countryside from ‘encroachment.
4. Preserve the setting and special character of historic towns.
5. Assist in urban regeneration, by encouraging the recycling of derelict and other urban land ie Brownfield Sites. Inappropriate development. (Page 122. Clause 10.8) Specifically states that the construction of new buildings in the Green Belt is generally considered to be inappropriate development.
The Hullbridge Residents Association respectively request that Rochford District Council adhere to these policies and review the New Local Plan Document. It may be appropriate to classify this as “Special Measures” and allow the intervention of a Planning Inspector to adjudicate.

Stakeholder Ref: CP15678E Community Representative Ref: 29007

Section 11. Detailed Policy Considerations. Pages 142- 165
Page 142. Clause 11.2 Mix of Affordable Homes

In HRA discussions with a developer we were advised that the RDC stated that the Core Strategy and the Land Development Framework were ‘out of date’ therefore some clauses were not applicable.
The same situation applied to discussions when applied to the Localism Act. The Core Strategy and the NPPF are evident in many statements in this new Local Plan document, so, we consider there has been no change in the above main documents, action is necessary.

Page 155. Clause 11.45 Brownfield Sites. HRA have taken into account clauses 11.45/ 46 and taken into consideration that all Brownfield sites must have priority. NPPF paragraph 89 and Policy DM10 on brownfield development should be an over-riding factor when producing these documents. We refer you to the ‘ambitious’ clauses stipulated in the LDF Management Submission Document- Clause 3 page 33- The Green Belt and Countryside – Vision. Short term. The first paragraph stipulates the “openness and character” of the Rochford Green Belt continues to be protected. Constant reference by our MP Mark Francois has been ignored which places him in an awkward position.

Page 164. Contaminated land. Cl 11.77 to 11.81. Specific example of for
Nevendon Yard Breakers Yard, Lower Road, Hullbridge. Proposed 90 units.
This site is contaminated over a 70 year period and the costs of eradication will be high. The outline application plans are presently delayed for that reason while a historical document is being prepared.

LOCALISM ACT 2011 chapter 20. Item 2.1 (5th bullet point)
The ‘Localism Act’ was brought into force in 2011, the community did not have the opportunity to apply the clauses of this act. This act stipulates that the Local Community has: the ‘right to challenge’ (Part 5, Chapter 2, Clauses 81 to 86).


End of Appeal For Withdrawal.