New Local Plan: Spatial Options Document 2021

INTRODUCTION
1.1 These representations have been prepared by Pegasus Group on behalf of Taylor Wimpey Strategic Land in respect of their land interests in Rochford District Council (RDC).

1.2 These representations are submitted in response to the current Rochford Local Plan Regulation 18 ‘Spatial Options' consultation, which sets out the different growth
strategy options that could be pursued by the Council in the emerging Local Plan.

The evidence base accompanying the Spatial Options document includes a Site Appraisal Paper which identifies the suitability of potential sites for allocation, including Taylor Wimpey’s interests at:
• Site Reference CFS074: Land South of Mount Bovers Lane, Hawkwell

1.3 The purpose of these representations is primarily to respond to the questions raised by the consultation to ensure there is a sound basis for emerging policies, as well as to support the most sustainable growth options of those set out in the consultation and reaffirm the deliverability (suitability, availability and viability) of
the above site and the exceptional circumstances in support of a minor revision to the Green Belt alongside the provision of a site-specific policy that allocates Land
South of Mount Bovers Lane, Hawkwell, for residential development in the emerging Local Plan.

1.4 These representations build upon and should be read in conjunction with Taylor Wimpey’s previous representations to the Rochford Local Plan-making process, which included high-level technical assessments and an Illustrative Framework Plan. These early representations explained the opportunities available at the above site to deliver a high-quality and sustainable residential development with the ability to contribute positively towards the District’s significant housing needs.

2. SPATIAL OPTIONS DOCUMENT
2.1 This section responds to questions posed by the Spatial Options consultation in respect of Taylor Wimpey's interests in Rochford.

Question 1: Are there any other technical evidence studies that you feel the Council needs to prepare to inform its new Local Plan, other than those listed in this section?

2.2 The technical evidence that has been prepared and is yet to be prepared by the Council is agreed as being required to inform the preparation of a sound Local Plan
capable of effectively addressing local housing need. It is important to ensure the evidence is prepared under a robust and appropriate methodology and is subject
to scrutiny.

2.3 It is noted that the list of evidence includes a Settlement Role and Hierarchy Study (2021); this document is also referenced elsewhere within the Spatial Options document. However, this document is not available on either the consultation webpage or on the full evidence base webpage. This document should be made available for public review and Taylor Wimpey reserves the right to comment further once this document has been made available.

Question 4: Do you agree with the strategic priorities and
objectives we have identified? Is there anything missing from the strategic priorities or objectives that you feel needs to be included?

2.4 The strategic objectives identified by the Council are agreed as being broadly logical and suitable for guiding the formulation of strategic policies within the emerging
Local Plan. As will be explored later in these representations, Taylor Wimpey will be able to contribute towards achieving the objectives relevant to residential
development. In particular, Strategic Objective 1 (to deliver sufficient, high quality and sustainable homes to meet local community needs) and Strategic Objective 2
(to plan for the mix of homes needed to support RDC’s current and future residents) will be met through the delivery of a wide range of new open market and affordable homes. It is agreed that the delivery of new homes should be assigned great importance, as the new housing will help to meet existing housing need, improve
housing affordability for all and aid in meeting the economic objectives of achieving new business growth.

2.5 Taylor Wimpey support the reference in Strategic Objective 1 to the need to prioritise the development of previously developed land. However, it should also be
acknowledged that sufficient brownfield sites are not available to meet the District's minimum housing needs in full, as stated in the Spatial Options document and
supported by the RDC Urban Capacity Study (2020). It should be referenced that the National Planning Policy Framework (NPPF, 2021) allows for changes to Green
Belt boundaries through the Local Plan-making process where exceptional circumstances exist (paragraph 140) and where this promotes sustainable patterns of development (paragraph 142). In a district where approximately 70% of the land is Green Belt, some release of Green Belt land may be necessary in appropriate locations to achieve sustainable patterns of development in line with the NPPF.

Question 5: Do you agree with the settlement hierarchy
presented? If not, what changes do you think are required?

2.6 As mentioned in answer to Question 1, the Settlement Role and Hierarchy Study (2021) does not appear to have been made available on the Council's website at the time of writing. Our answer to Question 5 is therefore given without a review of this document, which forms an important part of the evidence base in relation to the specific matter of the settlement hierarchy. The adopted Core Strategy categorises Hockley (including Hawkwell) as a Tier 1 settlement, alongside
Rochford and Rayleigh. The proposed separation of Rayleigh into Tier 1 by itself does not necessarily mean Hockley (including Hawkwell) is not as sustainable. It
cannot be stated at this time whether the settlement hierarchy has been derived using a robust and objective process until the Settlement Role and Hierarchy Study
has been reviewed.

2.7 Notwithstanding the above, Taylor Wimpey considers the settlement hierarchy presented within the consultation document should identify the settlement of
Hockley (including Hawkwell) at or near the top of the settlement hierarchy (i.e. Tier 1 or 2) as per the adopted Core Strategy (2011). This would be commensurate
with the sustainability of this settlement in terms of the important services and facilities required to meet day-to-day needs that are available within accessible
distance for residents of this settlement. Hockley (including Hawkwell) is able to sustainably support additional growth, and its position within the settlement
hierarchy is agreed in that sense. However, the Local Plan process going forward should take care to appreciate that the sustainability of a settlement is not fixed; it can be bolstered as a result of new and additional development, which can help to support the provision of new services or support the vitality of existing services through an increase in use and custom.

Question 6: Which of the identified strategy options do you consider should be taken forward in the Plan?

2.8 Taylor Wimpey supports the aim of the Council to ensure sufficient growth takes place over the local plan period to meet local housing need requirements as based on the use of the standard method to calculate the minimum housing needs for the District in line with paragraph 61 of the NPPF (2021). The Spatial Options document identifies a housing requirement of 7,200 homes (between 2020 – 2040) based on the standard method (i.e. 360 dwellings per annum).

2.9 Moreover, the consultation identifies a potential growth option of up to 10,800 new homes (2020 – 2040), representing the Standard Methodology + 50% which could help drive local economic growth or address unmet needs from elsewhere.

2.10 Taylor Wimpey strongly supports the Council's ambition to explore the opportunity to accommodate additional growth above that required by the standard method, to take on unmet need from neighbouring authorities in accordance with the NPPF requirement for Local Plans to be positively prepared. The neighbouring authorities are highly constrained both geographically and spatially, such as through large areas of Green Belt and areas of high flood risk. In general, the neighbouring
authorities have faced significant challenges in delivering sufficient levels of housing to meet identified housing needs. Southend-on-Sea to the south of Rochford District is particularly constrained with tight boundaries leaving limited available space for new development. Southend has a minimum housing requirement using the Standard Methodology of 1,180 new homes per annum and highlighted within their recent Local Plan Reg 18 consultation (2019) that even with Green Belt release, Southend will only be able to deliver around 20,000 new homes and that to meet their full requirements, neighbouring authorities such as Rochford will need to assist in the delivery of the additional 3,620 dwellings in the period 2020-2040. Rochford District will therefore need to make all possible efforts to accommodate housing above the levels required by the standard method to encourage economic growth and/or meet unmet needs arising from neighbouring authorities, acknowledging that this is a minimum requirement in light of the national priority to significantly boost the supply of housing in line with paragraph 60 of the NPPF. This will ensure the Local Plan is capable of meeting both Rochford District's needs as well as unmet need arising from Southend-on-Sea.

2.11 Taking the identified strategy options in turn. Option 1 (Urban Intensification) would not deliver a sufficient level of housing to meet identified needs, and it is
agreed that following this strategy would not result in a Local Plan being put forward that is sound in accordance with national policy. The strategy also relies too heavily
on committed developments and there is a risk that these developments will not deliver the expected levels of housing during the Plan period, with significant adverse social and economic impacts on the District as a result.

2.12 Option 3 (Concentrated Growth) is also not supported. It is considered that pursuing a growth option that focuses solely on the three towns Rayleigh, Southend and Rochford, would not lead to a sustainable level of growth. The Plan should seek to meet the needs of residents across the entire District; existing residents are likely to want to buy a home close to their existing ties to the local community and family. New growth should therefore be sensibly dispersed across the District to all settlements. Furthermore, Option 3 would lead to a high reliance on a few key strategic sites. Such large scale sites are likely to have slow rates of delivery; this
would make it difficult to meet the local housing requirement and maintain the rolling 5-year supply of housing required by paragraph 68 of the NPPF. Strategic
sites may also be subject to other risks to delivery, such as viability if the sites are also required to fund pieces of strategic infrastructure. In addition to delivery, this may also affect the level of affordable housing such strategic sites are able to deliver.

2.13 Option 2 (Urban Extensions) is strongly supported as it presents a strategy that would allow for sustainable growth to take place across the District, including the
organic growth of smaller settlements. This would allow the delivery of the Districts local housing needs as required by national policy for a sound Local Plan to be
adopted. The delivery of housing to meet local need would ensure the exceptional circumstances required for the release of land from the Green Belt could be met. It
is considered reasonable to disperse growth to all settlements as guided by the settlement hierarchy. This would ensure growth takes place in the towns and large
settlements that have the services and facilities needed to sustainably support a higher level of growth, while also ensuring smaller rural settlements can organically
grow in the manner required to sustain the vitality of the villages and meet the housing needs of local residents.

2.14 Taylor Wimpey is also in broad support of Option 4 (Balanced Combination) which combines elements of the above three options. A balanced combination of all
options would negate the negative outcomes of Option 1 not delivering sufficient levels of housing growth, as well as the risks associated with Option 3's reliance on a few key strategic sites. It would still allow for sustainable growth to take place in a dispersed manner across the District. It would however be key to get the balance
between the different options correct. It may be that under option 4, there is a need to ensure sufficient smaller urban extensions are allocated so they can be
brought forward early in the plan period to ensure there is no heavy reliance on the delivery of large strategic sites – as there are still risks associated with under-
delivery on large sites. A balanced approach to allocating a variety of sites both in terms of size and location will also have far greater potential to deliver a wide mix
of housing types and styles.

Question 9: Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and coastal change wherever possible? How can we best protect current and future communities from flood risk and coastal change?

2.15 In answer to the first part of question 9, Taylor Wimpey agrees that a sequential approach needs to be applied in allocating sites, as required paragraph 161 of the NPPF. This should be recognised as placing a further constraint on potential suitable land available for development and further necessitating the release of suitable Green Belt to ensure sustainable development can take place.

Question 11: Do you agree we should require development to source a percentage of their energy from low-carbon and renewable sources? Are there other opportunities in the District to supply low-carbon or renewable energy?

2.16 Taylor Wimpey fully supports the transition towards a zero carbon economy and for new development to be as sustainable as possible, which includes new homes
that are energy efficient and minimise carbon emissions. Taylor Wimpey is committed to being a sustainable housebuilder and continues to incorporate sustainability into their business practices, helping to create better homes and communities and a stronger business for the longer term.

2.17 It should be recognised in the emerging Local Plan that before thinking about how 'green' the energy used is, it should first be considered how energy use itself can
be minimised. This includes ensuring the construction of homes is undertaken in a manner that allows the effective retention/insultation of heat in the winter and
natural cooling in the summer, ensuring less energy is required to heat the home and take a fabric first approach in the design of houses to further improve energy efficiency. All of these measures are secured under the relevant Building Regulations, an uplift to which will be secured through the implementation of the
forthcoming Future Buildings Standards.

2.18 The need to require development to source a percentage of their energy requirement from low-carbon and renewable sources should be assessed against
the above energy efficiency requirements. The actual percentage should also be calculated with regard to potential impacts on the viability of future developments,
and the financial costs for implementation will need to be considered in the Local Plan Viability studies.

Question 12: Do you agree we should require new development to achieve energy efficiency standards higher than building regulations? What level should these be set at?

2.19 As explained above, the forthcoming new Building Regulations, which all development will be required to comply with, will ensure that all new homes that are built in the future will be built to a high energy efficiency standard. There is considered to be no beneficial need to require energy efficiency standards above those required by the new Building Regulations which will be in place upon adoption of the Local Plan. If the Council is to consider applying higher energy efficiency standards, robust evidence will be required supporting such a requirement. The evidence should include an assessment demonstrating no adverse impact on the
viability of future proposed developments.

Question 14. Do you consider that the plan should include a placemaking charter that informs relevant policies? Should the same principles apply everywhere in the District, or should different principles apply to different areas?

Question 15: Are the principles set out in the draft place-making charter the right ones? Are there other principles that should be included?

2.20 In answer to question 14, Taylor Wimpey has no objections with a District-wide place-making charter that can form the basis for site-specific decision making. The
importance of good design in creating attractive and liveable places is wellunderstood. The place-making charter should clearly appreciate that each site is
unique, with different contexts, constraints and opportunities that will need to be taken into account.

2.21 However, it is not entirely clear what policy position such a charter would hold in the Local Plan and the level of consideration the decision maker will need to give
to the character. Thus, in answer to Question 15, it should be made clear how the charter should be read in relation to specific policies. Then it would be relevant to
consider what principles are appropriate to contain in a charter. At this stage, it is considered that any charter included as guidance should be high-level and
overarching, with specific detail to be provided in the accompanying development management policies. This will avoid the duplication of local planning policies, as
encouraged by paragraph 15 of the NPPF. The local plan policies themselves will need to consistent with the relevant provisions of the NPPF and national guidance.

Question 16a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
Question 16b. If yes, do you think it is more appropriate to have a single design guide/code for the whole District, or to have design guides/codes/masterplans for individual settlements or growth areas?
Question 16c. What do you think should be included in design guides/codes/masterplans at the scale you are suggesting?

2.22 The need to produce design guides, codes or masterplans alongside the new Local Plan is questioned. The production of such documents is likely to take considerable time, particularly if the Council intends to seek to adopt or endorse a design document for each proposed allocation. This would inevitably delay the Local Plan process and delivery of new homes as the Council's resources are drawn away.

2.23 Instead, Taylor Wimpey suggests that design codes or masterplans should only be encouraged at such an early stage for large strategic urban extensions that are of a scale and mix of land uses where a design code document would be helpful in regularising design principles across the entire site and/or ensuring a coordinated approach to the delivery of strategic allocations where multiple landownerships/interests are present.

2.24 For smaller scale extensions and developments (i.e. single ownership developments of <500 dwellings), it is considered that the masterplans and other design material that is submitted at the planning application stage, which may include Design Codes prepared by the Applicant in consultation with RDC and the local community at the Planning Application stage, would be sufficient for allowing the Council to provide input and ensure the correct design principles are being delivered.

Question 17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes and tenures of housing?

2.25 Taylor Wimpey considers that proposed Option 2 would provide a suitable approach to address the District’s housing need. This option would allow an element of certainty that overall housing needs will be met, while also allowing flexibility for local site-specific factors to influence the housing mix a development provides at the application stage. These factors could range from site-specific environmental or technical constraints and opportunities to local market intelligence and demographics indicating a need for certain types and tenures of housing. Option 2 would align with the NPPFs objective of creating strong, vibrant and healthy
communities (paragraph 8) that are mixed and well-balanced (paragraph 63).

2.26 However, it is considered that Option 3 would also operate well in conjunction with Option 2. Allocating specific sites for specialist housing for older people and selfbuild and custom-build housing in particular would allow the housing need to be addressed where it is most needed, which is in line with the recommendations of
the Planning Practice Guidance.

2.27 Taylor Wimpey further support Option 5 which requires all homes to be built to Nationally Described Space Standards, Option 6 requiring all homes to meet Part M4(2) (accessible and adaptable homes), and Option 7 requiring a suitable proportion of new homes to meet Part M4(3) (wheelchair user dwellings). However,
as is required by the NPPF (footnote 49) and supporting national guidance, these options will require sufficient evidence to be gathered and provided by the Council
to support the need for these requirements, and whether it is appropriate for all homes to meet these requirements rather than a proportion of new homes. As footnote 49 states, the Council will need to demonstrate through robust evidence that there is an identified need that would be met through the application of the Part M4(2) and Part M4(3) optional standards. The need to apply the internal space standards must also be justified. The Planning Practice Guidance expands on this to explain that the evidence produced must also take into consideration viability and site-specific factors in addition to need, ensuring that the application of these additional standards does not risk the delivery of new homes.

Question 31. Do you consider net gains for biodiversity are best delivered on-site or off-site? Are there specific locations or projects where net gain projects could be delivered?

2.28 Taylor Wimpey considers it is for the Council to undertake research and identify a suitable pipeline of sites towards which off-site biodiversity net gain contributions could be made. Biodiversity net gain should be delivered on-site wherever possible; however the possibility of off-site net gains should not be discounted for developments that are constrained geographically or by viability or other factors. Taylor Wimpey is committed to protecting and enhancing the biodiversity of its sites wherever possible.

2.29 Taylor Wimpey recognises that climate change, declining nature and other environmental problems are increasingly becoming a threat to the wellbeing of
people today and future generations. In respect of Land south of Mount Bovers Lane, Hawkwell (CFS074), Taylor Wimpey has commissioned an initial Phase 1 ecology survey and assessment (Appendix A) which demonstrates the potential for a measurable biodiversity net-gain to be delivered on the site through habitat
creation and restoration. Developments which can demonstrate Biodiversity Net Gain should be looked upon favourably by RDC both when allocating sites within
the emerging Local Plan and when determining schemes at Planning Application stage.

Question 34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure?

2.30 In respect of Option 3 which requires new developments to provide on-site green and blue infrastructure, and/or contribute towards off-site green and blue infrastructure. Taylor Wimpey supports the provision of such local infrastructure, which can help to mitigate the impacts of flooding and contribute towards creating and improving wildlife habitats and enhancing the character and appearance of newdevelopment.

2.31 Land south of Mount Bovers Lane, Hawkwell (CFS074), is capable of contributingtowards the objective of creating enhanced local green infrastructure. As indicated on the Illustrative Landscape and Ecological Masterplan (Figure 9, Appendix B) the site has the potential to enhance the existing vegetation on the site through new planting such as shrubs, wildflower grassland and hedgerow. The landscape proposals also provide a new community orchard, new woodland planting and tree lined streets. These improvements to green infrastructure would help deliver the objectives of the South Essex Green and Blue Infrastructure Strategy, in particular the creation of the Central Woodlands Arc Regional Parkland and enhancements to the Upper Roach Valley to create a successful ‘green lung’ through the District.

Figure 1: Illustrative Landscape and Ecological Masterplan
[see document for image]

2.32 This local green infrastructure would enhance existing biodiversity, create an attractive landscaped setting for the new homes and enhance the leisure
opportunities available for both new and existing residents in Hawkwell, thereby delivering wider health and well-being benefits also. The site provides opportunities for links to be provided to the existing Public Rights of Way network located on the site boundaries, which will improve permeability and ease with which access can be gained to the wider countryside.

2.33 In terms of blue infrastructure, the submitted information further indicatively shows that the scheme has the potential to provide a network of ponds or swales that could create a new 'blue' corridor within the open space to the west. These ponds would complement the SuDS basins that will be provided within the developable,
eastern part of the site to deliver additional benefits. The blue infrastructure would help to mitigate the risk of flooding by assisting with the flow of water away from
homes, as well as provide ecological enhancements and assist in creating a naturalistic open space area to be enjoyed by residents.

2.34 It is noted that Option 3 states 'certain new developments' will be required to provide or contribute towards local green and blue infrastructure projects. As this objective is developed into a policy, it will be important to ensure that the threshold where Option 3 will apply to developments is made clear.

Question 35. With reference to the options above, or your own options, how can we address the need for sufficient and accessible community infrastructure through the plan?
Question 36. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new or improved community infrastructure?

2.35 Taylor Wimpey supports in principle the options that are suggested for meeting community infrastructure needs through the Local Plan. The options should be
maintained as being non-exclusive, so flexibility can be maintained to allow infrastructure needs to be met in the most appropriate manner for each settlement and site location.

2.36 The infrastructure that will be required to support the delivery of Taylor Wimpey's interests in Hawkwell will be set out in further detail in the Infrastructure Delivery
and Funding Plan that is to be prepared by the Council. However, Taylor Wimpey is committed to investing in complementary infrastructure that is evidentially
required to support the delivery of new homes at this location. It is noted that
Hockley (including Hawkwell) is a sustainable settlement containing many of the services and facilities required to support the day-to-day needs of residents.
Contributions could be made towards this existing infrastructure as required to ensure sufficient capacity exists for the services to continue supporting existing and
new residents. The site also has the potential to provide new community infrastructure, such as land for education and/or healthcare which will complement existing facilities, subject to viability and clear evidence that additional infrastructure is required.

Question 38. With reference to the options above, or your own options, how do you feel we can best meet our open space and sport facility needs through the plan?
Question 41. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver improvements to open space or sport facility accessibility or provision?

2.37 The proposed Option 4 is of direct relevance to Taylor Wimpey in this instance, as it suggests requiring new developments to provide new open space or contribute towards enhancing existing infrastructure. Taylor Wimpey fully supports the objective of ensuring the open space and recreation needs of residents are met.

2.38 As illustrated on the submitted Development Framework Plan (Appendix C), the masterplanning for the site has been heavily influenced by the landscape strategy. This strategy seeks to maintain and enhance existing green infrastructure as explained in our response to Question 34 above. Nearly 50% of the site area is to
be maintained as green infrastructure and public open space, significantly above planning policy requirements. This will have the dual benefit of creating a defensible
boundary with the Green Belt, and creating new public open space to be enjoyed by all members of the local community, delivering enhanced opportunities for
recreation and social interaction, alongside the health and well-being benefits this brings.

2.39 In addition to the amenity green space that can be enjoyed for both leisure and activity, circular footpaths will be provided around the open space to encourage
walking within and through the open space. New woodland and orchard planting will provide visual amenity within the open space, as will the 'blue corridor' of ponds or swales. Formal play areas will be provided in accessible locations within the scheme, that will be open for use by all residents both new and existing. This will
therefore help to increase access to play space for residents of Hockley (including Hawkwell) in the vicinity of site CFS074. The objectives put forward by the Council are supported by Taylor Wimpey as contributing towards meeting the requirement in the NPPF (paragraph 92) for healthy places with accessible green infrastructure.

Question 46. With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley? How can we also ensure our village and neighbourhood centres remain vibrant?

2.40 Taylor Wimpey supports the objective of ensuring the continued vibrancy of the District's town and neighbourhood centres, including those at Hockley and
Hawkwell. We do not seek to provide an opinion on how the Council can best plan to achieve this objective, however it is considered important to understand that
new growth is required if vibrancy and vitality is to be maintained. This will bring new custom for existing businesses in centres, and provide opportunities for new
business to come forward.

Question 51. With reference to the options above, or your own options, how do you feel we can best address our transport and connectivity needs through the plan?

2.41 Taylor Wimpey considers the options presented are logical approaches to explore further towards the goal of improving connectivity within the District. Option 2 is
relevant to Land South of Mount Bovers Lane, Hawkwell, and Taylor Wimpey would support appropriate contributions that are evidenced by a robust Infrastructure Delivery Plan as being required to support the development.

2.42 It is to be noted however that Land south of Mount Bovers Lane (CFS074) is located in a sustainable location that benefits from convenient access to local services and facilities via various modes of sustainable travel. This is demonstrated in the Sustainability Appraisal which accompanies these representations (Appendix D).

2.43 There are pedestrian and cycling routes leading towards the centre of Hawkwell where several services are located within comfortable walking or cycling distance of the site. This would reduce the reliance on day-to-day travel by private car. For locations further afield, travel by bus and train is available from bus stops adjacent to the site and Hockley train station located around 20 minutes' walk from the site. Both modes of public transport receive frequent services.

Question 58a. Do you agree with our vision for Hockley and Hawkwell? Is there anything you feel is missing?

2.44 The vision statement presented is broadly supported and as highlighted above site CFS074 provides clear opportunities to contribute positively towards the green lung of the Upper Roach Valley through the provision of new woodland landscaping and
biodiversity net gain. Moreover, the aim to address housing affordability is fully supported, but will only be addressed through the provision of viable market
housing developments capable of delivering Affordable Housing.

Question 58b. With reference to Figure 46 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Hockley and Hawkwell?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare,
allotments, other]
iv. Other

2.45 As mentioned in answer to Question 6, Taylor Wimpey supports following a strategy that allows growth in all settlements across the District, including Hockley and Hawkwell, at a level that is appropriate to the sustainability of each settlement. Hockley and Hawkwell is identified within the adopted Core Strategy (2011) as a
Tier 1 settlement, and the current Spatial Options Document proposes Hockley (including Hawkwell) as a Tier 2 settlement below only Rayleigh. This is
commensurate with the settlement being one of the most sustainable in the District, and its ability to support additional housing. It is clear that Hockley and
Hawkwell are eminently sustainable, as illustrated on Figure 43 which shows that residents are within walking distances of the range of services and facilities that
are available.
[see attached document for image]

2.46 For this site in particular, the following range of services and facilities are located close to the site, as further expanded within the accompanying Sustainability
Appraisal (Appendix D):
[see attached document for table showing accessibility from site to key destinations and facilities]

2.47 Hockley Train Station is also located just 1.5km / 20-minutes walking distance to the north.

2.48 Hockley, which is in close proximity to the site, supports a further range of local retail and employment opportunities.

2.49 On this basis, Taylor Wimpey strongly supports the 'allocation' of site reference CFS074 for up to 400 new homes and significant green infrastructure as illustrated
below. The site is also capable of contributing towards appropriate on-site or offsite social / physical infrastructure if further evidence demonstrates a need for such infrastructure.
[see attached document for masterplan of site]

Site Deliverability
2.50 The suitability and benefits of this site have been comprehensively presented in previous submissions to the Local Plan-making process, including in
representations to the Regulation 18 Issues and Options Consultation in 2018. This submission was accompanied by technical input and Taylor Wimpey are committed
to working collaboratively with the Council to ensure the timely delivery of the proposed allocation. The following seeks to further reiterate the deliverability and
suitability of the site for residential development in response to the 'scoring' of the site in the RDC Site Appraisal Paper (2021) as presented below. The scores given follow a scale as replicated in the figure below
[see attached document for screenshot of site appraisal criteria]

Drainage
[see attached document for screenshot of site appraisal scores]
2.51 The site is located within Flood Zone 1 (lowest risk) as defined by the Environment Agency. The site is therefore considered sequentially preferable for residential development in flood risk terms, and the score of 5 (best performing) is agreed with.

2.52 The score of 2 for 'critical drainage risk' appears to have been informed by a highlevel view of the surface water flood risk for the site. Mapping on the Environment
Agency long term flood risk website illustrates that the central valley of the site is associated with low to medium risk of flooding from surface water, with some areas
on the eastern boundary and areas within the western half of the site being associated with low to high risk of flooding from surface water.
[see attached document for screenshot on EA surface flood risk map]

2.53 However, this is a matter that can be suitably addressed through any future planning application, which would be supported by a surface water drainage
strategy incorporating Sustainable Urban Drainage Systems (SuDS). The Illustrative Landscape and Ecological Masterplan (Appendix B) illustrates how the
matter of surface water flood risk can be mitigated, through the inclusion of SuDS basins and swales through the centre of the site where the valley is located. The
location and design of the basins and swales will be subject to further detailed drainage assessment, however it is considered that a scheme can be designed that
effectively mitigates the risk of surface water flooding.

Green Belt and Landscape Impact
[see attached document for screenshot of site appraisal criteria]

2.54 The site is located within the Green Belt, albeit being directly adjacent to the existing settlement edge of Hawkwell. It is acknowledged that the Green Belt
designation carries significant weight as a material consideration, with the NPPF being clear that Green Belt boundaries should only be altered in exceptional
circumstances (paragraph 140). The site is also located within the Upper Roach Valley Landscape character area which seeks to protect a ‘green lung’ and landscapes of value (noting it also aims to promote recreation).

2.55 As explored earlier, Rochford District is highly constrained with limited opportunities to accommodate sufficient levels of growth outside the Green Belt.
The evidence base produced by the Council indicates there are not sufficient nonGreen Belt sites available to meet local housing needs. The Urban Capacity Study
(2020) found that urban sites may deliver between 3,300 and 5,000 sites over 10-
15 years. The Council has identified the need for a minimum of 7,200 new homes to be delivered over the Local Plan period, and at least 10,800 homes when a buffer is applied and the potential to accommodate unmet need from neighbouring authorities is taken into account, as Taylor Wimpey considers is required.
Furthermore, the most sustainable sites that are going to be available for potential allocation and development will be within the Green Belt, as the settlements identified in the settlement hierarchy as being the most sustainable and capable of accommodating new growth lie within the Metropolitan Green Belt.

2.56 There will be harm associated with the release of Green Belt land. However, the inherent shortfall in brownfield land available for development and the ability of Green Belt land to delivery sustainable patterns of development provides, in our view, the exceptional circumstances required to amend the Green Belt boundary.
The Green Belt Study (2020) prepared by the Council concludes (the Stage 1 Assessment) by stating at paragraph 3.39 that other than a few pockets of Green
Belt, the majority of the assessed land continues to serve the Green Belt purposes well.

2.57 It is noted here that our 2018 submissions included an independent Green Belt Assessment of the site which concluded that the site makes limited or no contribution to four of the Green Belt purposes, except for purpose 3 'safeguarding the countryside from encroachment' to which it was considered a partial contribution is made. Taylor Wimpey considers this appraisal remains valid and the value of this site to the Green Belt is limited and that any harm arising from its removal from the Green Belt would also be limited.

2.58 Notwithstanding this, paragraph 3.39 of the Green Belt Study (2020) does go on to state that the most sustainable sites for potential allocation may be located in areas that make a strong contribution to the Green Belt purposes. The contribution that a site makes must therefore be weighed against other relevant factors that
determine the suitability of a site for development, such as the existence (or lack thereof) of site-specific constraints, proximity to sustainable settlements and
transport connectivity.

2.59 A Landscape and Visual Appraisal, including Green Belt Appraisal (Appendix B), has been prepared to accompany these representations. The report considers the landscape and visual constraints the site is subject to, based on the potential impacts arising from the proposed development. This appraisal has in turn informed the creation of an Illustrative Landscape Masterplan, which demonstrates that a residential scheme that is led by robust landscape principles can be created that will be 'physically contained and have clear defensible boundaries', as well as make 'a positive contribution to the recreational aspects of the landscape in respect of the Upper Roach Valley.' A significant area of open space is proposed on the western half of the site (far in excess of policy requirements) which will further
contain the built form to remain in line with the existing extension of the settlement edge into the landscape.

2.60 With the implementation of the proposed landscape strategy, which will be formulated further as detailed design takes place, to create an appropriately designed residential scheme, the Appraisal demonstrates that the site would have only limited landscape and visual effects at a localised level and that such impacts can successfully be avoided or reduced through appropriate mitigation. The proposed inclusion of substantially improved areas of local green and blue infrastructure in addition to open greenspace will also allow the creation of a defensible Green Belt boundary, limiting the risk of additional 'sprawl' as well as creating an appropriate interface between the settlement edge and the wider
countryside.

2.61 Consequently, development of site CFS074 would complement the character of the wider landscape context and enhance the function of the Upper Roach Valley's as
a 'green lung' through the District. Any limited impacts can be mitigated and enhanced through the proposed landscaping strategy, with recreational benefits
arising from the proposed green infrastructure which will provide new health and wellbeing outcomes for existing and future residents of Hawkwell. An appropriate,
robust and enduring boundary to the Green Belt can therefore be created.

2.62 As such, the low scores given on Green Belt and Landscape Impact by the RDC Site Appraisal are challenged for the reasons set out above and should not preclude consideration of the site for allocation. Notwithstanding this, the discussion on other factors in answer to question 58b clearly demonstrates the suitability and sustainability of the site; this must be weighed against the potential harm caused to the Green Belt and in our opinion provides sufficient reason for further consideration of this site in later Local Plan stages.

Biodiversity
[see attached document for screenshot of site appraisal criteria]
2.63 Taylor Wimpey supports the scores given to the site relating to biodiversity. A Preliminary Ecological Appraisal has been undertaken which confirms that that the site is of limited ecological interest.

2.64 The proposed strategy set out in the Illustrative Landscape and Ecology Masterplan would therefore have the benefit of providing a measurable improvement of habitat and biodiversity net gain on the site.

2.65 The site itself is not covered by any statutory habitat designations. However, the site is located close to the Hockley Woods SSSI which is a nationally designated
ancient woodland. While development of the site would not result in any direct impacts on the SSSI, there is the potential for indirect impacts through additional
recreational pressure resulting from new residents. The site proposes to provide a significant amount of greenspace on the site, which will effectively mitigate the
recreational pressure that might otherwise be generated on surrounding environmental designations.

Heritage
[see attached document for screenshot of site appraisal criteria]
2.66 The scores relating to heritage are not considered to be accurate. A Heritage Statement has been prepared (Appendix E) which contains an assessment of potential impacts arising from the proposed development on the historic environment. In terms of archaeology, a review of the available recorded data indicates that there are unlikely to be any below ground remains which are of
historical interest. The potential for significant archaeological remains from any historical period is considered to be low. The score relating to impact on
archaeology should therefore be a 5 (i.e. best performing), as any potential impacts can be comfortably mitigated by way of a planning condition at the planning
application stage, which would control development of the site until the desktop findings have been confirmed through further investigation.

2.67 In terms of built heritage, there are a few Grade II listed buildings in the vicinity of the site but only two that may be impacted by the proposed development. The
Grade II listed Sweynes Farmhouse is located north-east of the site, however it is considered the site does not contribute to the significance of this asset and is not
a constraint to development of the site. The Grade II listed Mount Bovers is located to the west and a small part of the site was historically associated with the function of the heritage asset. To preserve the significance of the listed building, it is therefore proposed that a setback is maintained in the western part of the site, with an associated enhancement of vegetation on the north-western boundaries. As the emerging masterplan for this site proposes the retention of the entirety of the western half of the site as open greenspace with significant new planting, this setback will be comfortably provided for and maintained and it is considered that there will be no impact on this designated heritage asset. The score relating to built
heritage should therefore be at least a 4 (better performing).

Sustainability
[see attached document for screenshot of site appraisal criteria]
2.68 The scores relating to the sustainability of the site are broadly agreed with, although a Sustainability Appraisal (Appendix D) has been prepared which refutes
the scores given on some elements, as will be explored below.

2.69 The existing bus stops are located close to the site boundary on Main Road and Hall Road, at most around 10 minutes' walk for homes located furthest from the Hall
Road bus stop – with most homes being located at a much closer distance. Given the close proximity and convenient access to bus stops the score should be a 5
(best performing).

2.70 Similarly, the score for access to bus services is currently too low and should be at least a 4 (moderate positive). The no.8 bus service provides a regular and frequent service (every 30 minutes) on a weekday, allowing convenient access towards Hockley Town Centre, Rayleigh, Southend-on-Sea and Great Wakering. This bus service provision also means the score for access to town centre should be at least a 4 (moderate positive) rather than 1 (negative), as Hockley town centre is very accessible from the site, if not by bus then also by walking and/or cycling.

2.71 Other bus services are also available, and whilst less frequent they provide travel options to other settlements. There are bus shelters available for 3 of the 4 closest bus stops to the site, with the potential for improvements to be made to encourage use of the bus services.

2.72 The bus services available include providing travel to Hockley train station, which is otherwise around 20 minutes' walk from the site. This is considered to offer good access, making travel by train to settlements further afield or for commuting a feasible option. Indeed, the station provides frequent and regular trains towards
Southend Victoria and London Liverpool Street. The score for access to train services should be at least a 5 (positive).

2.73 The score of a 5 for access to walking infrastructure is strongly supported; the site is extremely well-connected and as the evidence within the Spatial Options Document illustrates there are plenty of opportunities to walk to everyday services and facilities within Hawkwell or even to Hockley centre. The footways are of a good quality and attractive, being safe and traversable. The score of 3 (moderately performing) for cycling is accepted, as while the roads in the vicinity of the site are suitable for cycling to local facilities, there is no formal infrastructure that can be utilised to encourage cyclists with less confidence.

2.74 The relevance of the scoring for access to the strategic road network is not clear. The A127 and A130 are accessible from the site, and are of a similar distance from the current site as they are from elsewhere in the district. The sustainability of the site lessens the reliance on the strategic road network. Furthermore, this is a
residential scheme where trips for day-to-day needs will be made locally – the SRN is not as significant as it would be for an employment scheme.

2.75 Turning to the scores given for access to facilities such as primary school, healthcare and any other centre (in this instance Hockley centre). The scores given are broadly agreed with as they acknowledge the sustainability of the site given the close proximity of these services. It should be acknowledged however that
certain services within Hockley centre such as the Co-Op (Supermarket), Pharmacy and Post Office are very close to the site (around 10 minutes' walk) and could
therefore be given a score of 5 (best performing). Similarly, the Practice Hawkwell (health centre) is also around a 10-15 minutes' walk from the site and could also be given a score of 5 (best performing) rather than a 4 (moderate positive).

2.76 With respect to the secondary school, the closest is Greensward Academy which is up to 30 minutes' walk or 10 minutes' cycle from the site. However, the journey
can also be made by bus in around 11 minutes (not accounting for waiting time). This is considered to be relatively normal travel times for a secondary school, where journeys are made independently by older children by bike, bus or walking. The score of 1 should therefore be at least a 4 (moderate positive) to reflect this.

2.77 Turning finally to employment, the score of 2 (moderate negative) is contested. Firstly, there has been a noticeable shift to homeworking which means there is less need for reliance to be placed on workers needing to be close to their place of employment. Nevertheless, there are employment sites located in the north of
Hockley within an accessible distance from the site and regular train services into London from Hockley Station as highlighted above, and this score should therefore
be upgraded to 4 (moderate positive).

2.78 In summary, these representations expand upon previously made submissions to demonstrate that Land south of Mount Bovers Lane, Hawkwell, is capable of
delivering a residential development in a sustainable and accessible location. Exceptional circumstances exist for the Local Plan to release land from the Green Belt, and the evidence submitted demonstrates development of this site will not adversely harm the Green Belt and a sensitively designed landscape-led scheme will help to mitigate and enhance the local landscape and deliver biodiversity net gain, alongside recreational improvements and the associated health and wellbeing outcomes this brings for existing and future residents. The District, and Hockley (including Hawkwell) in particular, has a pressing housing need and
affordability issue, which the delivery of this site can contribute significantly towards addressing. The site is capable of being delivered in the early stages of the
new Local Plan period, and Taylor Wimpey is willing to collaborate closely with the Council to ensure this can be achieved.

Site Availability
2.79 The site remains under single ownership and comprises managed agricultural land on the southern edge of Hawkwell. There are no legal constraints to the availability of the land for development.

2.80 The landowner is willing to make the site available for development and the site is under option and being promoted by Taylor Wimpey, one of the UK’s largest housebuilders, through the emerging Local Plan in addition to engaging with local stakeholders as part of this process.

2.81 The expertise offered by Taylor Wimpey ensures that subject to the removal of the current Green Belt designation through the Local Plan-making process, that the site will be available for development immediately and capable of delivering new homes in the early part of the New Local Plan.

Site Viability
2.82 The site will be expected to contribute to the provision of infrastructure, through a variety of mechanisms, including Section 106 and Section 278 Agreements, Community Infrastructure Levy (CIL) and appropriate Planning Conditions, provided such conditions are necessary and relevant to the proposed development and also where Planning Obligations are:
i) Necessary to make the development acceptable in planning terms;
ii) Directly related to the development; and
iii) Fairly and reasonably related in scale and kind to the development.

2.83 The full Infrastructure requirements in relation to this site are as yet unknown but will be set out within RDC’s forthcoming ‘Infrastructure Delivery Plan’.

2.84 The site comprises managed agricultural land (i.e. Greenfield land) and accordingly, it is not anticipated that there will be any abnormal costs associated with the
development of this site as may be expected on previously developed (brownfield) land.

2.85 As such, and subject to further ongoing site investigations and review of RDC’s Infrastructure Delivery Plan, CIL, Local Plan Viability Assessments and emerging Planning Policy wording once finalised, which will provide further details with regards to likely infrastructure requirements arising from the development of the site, it is to be anticipated that the site will be capable of delivering the Council’s emerging policies, including with regards to Affordable Housing provision.

3. SUMMARY AND CONCLUSIONS
3.1 This representation has been submitted on behalf of Taylor Wimpey Strategic Land in support of their land interests at:
• Site Reference CFS074: Land south of Mount Bovers Lane, Hawkwell

3.2 The representations respond to the questions raised by the consultation to reaffirm the deliverability (suitability, availability and viability) of the above sites and set out the exceptional circumstances in support of a minor revision to the Green Belt. The representations support the taking forward of this site to create a site-specific policy that allocates the site for residential development in the emerging Local Plan to deliver a high-quality and sustainable residential development to contribute positively towards meeting the District’s significant housing needs.

3.3 Site CFS074 represents a deliverable site and Taylor Wimpey is keen to work collaboratively with RDC and local stakeholders in the preparation of the new Local
Plan to ensure a positive policy position for the site is taken forward to deliver real benefits for the local community and the District as a whole.