New Local Plan: Spatial Options Document 2021

1. INTRODUCTION
1.1 Rochford District Council is seeking feedback from interested parties on its identified ‘Options’ in the
New Local Plan: Spatial Options document.
1.2 Lee Evans Planning have been instructed to make representations on behalf of Ms Suzanne Redwood,
Mr Roger Lambourne and Mr Colin Humphries.
1.3 Section 2 sets out relevant extant Planning Policy considerations.
1.4 Section 3 reviews and comments on the Spatial Options document, including providing responses to
Questions outlined in the Consultation.

2. CURRENT POLICY POSITION
National Planning Policy Framework
2.1 The National Planning Policy Framework sets out the meaning and role of sustainable development and how planning can help to achieve it. At a very high level, the objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs.
2.2 A rising population and longer life expectancy requires growth and an increase in the volume and
choice of housing. The NPPF identifies the need to complement this growth with high standards of
design and to protect our built, natural and historic environments. The NPPF also highlights the
fundamental role that sustainable development plays in the plan-making and decision making process.
So that sustainable development is pursued in a positive way, at the heart of the Framework is a presumption in favour of sustainable development
2.3 The NPPF serves to provide a framework around which the community and the councils can produce
the local and neighbourhood plans, which reflect the needs and priorities of the community.
The National Planning Policy Framework must be taken into account in preparing the development plan, and is a material consideration in planning decisions.
2.5 Paragraph 8 of the NPPF reiterates the role of the planning system and the contribution it must make to realising sustainable development. Sustainable development has three dimensions to it; economic,
social and environmental.
• an economic objective – to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and
coordinating the provision of infrastructure;
• a social objective – to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering well-designed, beautiful and safe places, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being; and
• an environmental objective – to protect and enhance our natural, built and historic environment; including making effective use of land, improving biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate
change, including moving to a low carbon economy.
2.6 The NPPF considers in further detail the need to protect and improve the quality of the built, natural and historic environment. One aspect of this aim is to widen the choice of quality homes. This can be achieved through the plan-making process, as discussed in paragraph 11.
Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that:
a) all plans should promote a sustainable pattern of development that seeks to: meet the development
needs of their area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects;
b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:
i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or
ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when
assessed against the policies in this Framework taken as a whole.
2.7 Paragraph 60 notes the need to boost the supply of homes through land allocation. To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay.
2.8 Paragraph 61 outlines the approach to determining housing need. The New Local Plan; Spatial Options
document is unclear on the degree to which the duty to cooperate has been explored with neighbouring areas, suggesting that at present the assumption should be made that all identified housing need must be delivered within the district.
To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.
2.9 Each year the local planning authority will identify their supply of specific deliverable sites to provide the next five years of housing with an additional 5% buffer. This will allow for both choice and competition in the market. Developable sites that can accommodate for years 6-10 of the plan period and beyond will also be identified.
2.10 A 10% buffer should be provided “where the local planning authority wishes to demonstrate a five year
supply of deliverable sites through an annual position statement or recently adopted plan, to account for any fluctuations in the market during that year”.
2.11 A 20% buffer should be provided “where there has been significant under delivery of housing over the
previous three years, to improve the prospect of achieving the planned supply”. The NPPG elaborates
by stating that “A 20% buffer will apply to a local planning authority’s five-year land supply if housing delivery falls below 85%”.
2.12 If a five year supply of deliverable housing cannot be demonstrated policies relating to the supply of housing should not be considered to be up-to-date. All housing applications should be considered on the basis of a presumption in favour of sustainable development as has been discussed above. The most recent Authority Monitoring Report (draft 2019-2020), suggests that there exists a district housing need of 1,800 homes over a five year period (equating to 360 homes per year) and that the Council could at that time illustrate a 6.32 year housing land supply at a 5% buffer level, and 5.53 year supply at the 20% buffer, albeit it is noted that this was only draft and requires updating for the 2020-2021 period. The current supply is unknown but the Spatial Options document notes that the need for 360 homes per
year over the course of the Plan (20 years), equating to 7,200 homes total, remains. This figure does not include for assisting other districts in the duty to cooperate or any 5/20% buffer, so could well be higher. Notwithstanding this, there is a clear need to increase the allocation of housing land in the new Local Plan to illustrate the potential for 7,200 homes to be delivered.
2.13 Paragraph 73 highlights the opportunity for larger scale development and the benefits of this approach
in achieving the necessary supply of housing. It is possible that new settlements or extensions to
existing settlements can provide a route to sustainable development.
The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities (including a genuine choice of transport modes).
2.14 Paragraph 23 notes that Local Plans should plan positively for development by allocating sites for
development and identify land where development would be inappropriate due to its environmental or historic significance.
Broad locations for development should be indicated on a key diagram, and landuse designations and allocations identified on a policies map. Strategic policies should provide a clear strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period, in line with the presumption in favour of sustainable development. This should include planning or and allocating sufficient sites to deliver the strategic priorities of the area
2.15 Paragraph 138 of the NPPF refers to the purposes of the Green Belt;
Green Belt serves five purposes:
a) to check the unrestricted sprawl of large built-up areas;
b) to prevent neighbouring towns merging into one another;
c) to assist in safeguarding the countryside from encroachment;
d) to preserve the setting and special character of historic towns; and
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
2.16 Local Plans will be examined by an independent inspector before they are adopted. To be considered
ready for adoption they will need to be shown to be ‘sound’, as per paragraph 35 of the NPPF;
Local plans and spatial development strategies are examined to assess whether they have been
prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are
‘sound’ if they are:
a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
c) Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant. Rochford District Core Strategy and the Allocations Plan
2.17 The key strategic documents in the local development plan are the adopted Core Strategy 2011 and the Allocations Plan 2014. These are both dated documents and would be considered out of date where
the content conflicts with NPPF policy. Nonetheless, they provide a useful basis against which to subsequently consider the options in the New Local Plan consultation.
2.18 The following exerts are of interest;
District
2.41 “Failure to provide affordable housing that meets the needs of the District’s residents may lead to
continued out-migration, to the detriment of the vitality of local communities.” (p31)
Rayleigh
“The largest settlement is Rayleigh which, in 2001, was home to 30,196 people (38% of the District’s
residents at that time).” (p28)
Housing Development
2.39 “As well as directing housing growth to areas of need/demand, and away from unsustainable
locations subject to constraints, the Council must consider the relationship of housing growth to areas
of employment growth.” (p30)
Vision – Medium/Long Term “A range of high-quality, sustainable new dwellings that meet the needs
of local people of all social groups are in place and integrated into communities. The vast majority of
the District’s Green Belt remains undeveloped. New infrastructure has accompanied new residential
development, meeting the need of local communities.” (p41)
Policy H1 – the efficient use of land for housing
“The remaining housing requirement that cannot be delivered through the redevelopment of appropriate previously developed land will be met through extensions to the residential envelopes of existing settlements as outlined in Policy H2.” (p45)
The Green Belt
Housing Objective “Prioritise the redevelopment of appropriate brownfield sites for housing, to minimise the release of Green Belt land for development” (p41).
“In order to fulfil the requirements of the East of England Plan and to meet the housing need of the District, the Council is required to allocate additional land for residential development, including land, which is currently allocated as Green Belt, due to the limited supply” (p45).
“it must be also mindful of the need to maintain Green Belt as far as possible.” (p46)
2.19 The extant Core Strategy outlines a strong protection of the Green Belt, as per national policy. However, this was predicated on an old housing need and supply, which is now out of line with current demand
and what can be achieved through existing permissions, allocations, brownfield sites and windfall forecasts. Rayleigh is considered a focal settlement and one that has both a sizeable population already and the infrastructure to service those residents.
2.20 Notwithstanding the above, the Council recognised the need to review the designation of the Green Belt in the face of the relatively low housing need at the time the Core Strategy was drafted. It states;
The Council will continue to support the principles of restricting development in the Green Belt, as set out in PPG2, and will preserve the character and openness of the Green Belt. However, a small proportion of the District’s Green Belt will have to have its designation reviewed to allow the development of additional housing and business premises, taking account of the very limited
opportunities to accommodate further development within existing settlements.
2.21 This position regarding housing need and lack of land supply (before moving onto Green Belt land), will
be felt more acutely during the drafting of this new Local Plan.

3. NEW LOCAL PLAN: SPATIAL OPTIONS QUESTIONS
3.1 It is noted that in its introductory section the Spatial Options document considers the need to “coordinate the delivery of much needed housing”. It also states that;

“Rochford should consider every opportunity to meet its own housing needs within its own authority
area, with a focus on genuinely affordable housing that meets genuinely local needs”
3.2 Given the extent of Green Belt in this part of South East Essex, it is considered likely that as in Rochford,
surrounding districts will find it difficult to deliver their full quota of required housing land supply within
existing settlements and on brownfield land, i.e. there will be a need to use Green Belt. To this end it is
submitted that they will be unable to offer assistance to Rochford in providing surplus land to accommodate housing delivery. We support the Spatial Options document in the above assertion.
3.3 This will necessitate a review of Green Belt designation to a greater extent than that previously carried out with the adopted Core Strategy. As noted above, Green Belt serves 5 purposes; “to check the
unrestricted sprawl of large built-up areas, to prevent neighbouring towns merging into one another, to
assist in safeguarding the countryside from encroachment, to preserve the setting and special character of historic towns and to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.” It is submitted that where these matters are less acutely felt, and in those areas of lesser
landscape quality, new housing land allocations could be proposed within the currently designated Green Belt, to assist with achieving the necessary housing land supply. The Core Strategy acknowledges this approach;
The term ‘Green Belt’ refers to a planning designation and is not necessarily a description of quality of
the land. Land designated as Green Belt can include, primarily for historical reasons, developed land and
brownfield sites. As such, whilst it is considered that all land currently designated as Green Belt helps achieve the five green belt purposes as set out in the NPPF to at least a degree, some green belt land is less worthy of continued protection.
3.4 This is acknowledged in the New Local Plan: Spatial Options document, which considers 4no. spatial
options for delivery of necessary development and infrastructure. All but Option 1 would necessitate
the use of Green Belt.
Question 5. Do you agree with the settlement hierarchy presented? If not, what changes do you think
are required?
3.6 We support the settlement hierarchy presented. This focuses development at the most appropriate
settlements in the order of their ability to support new development. Rayleigh benefits from a strong existing resident mass and thus has a viability for growth and expansion of businesses and communities. We would submit that the majority of new development, and residential site allocations, should be around Rayleigh.
Question 6. Which of the identified strategy options do you consider should be taken forward in the Plan?
3.7 We support Strategy Option 2 and in particular Option 2a. This option provides a balanced response to the housing need of 7,200 – 10,800 dwellings (delivering between 8,700 to 10,700 dwellings), the necessary mass to support a good level of new infrastructure and facilities, and the need to minimise as much as possible the release of Green Belt for development.
3.8 Option 1 would not deliver the required housing land necessary to respond to the identified housing
need over the course of the Plan, and as discussed, it is considered unlikely that other surrounding districts would be able to assist with additional land. Option 3 would necessitate a significant release of Green Belt and would have a significant impact on the character of the surrounding Green Belt due to the size of a new villages/towns. As with to Option 3, Option 4 would require a sizeable release of Green Belt and significant impact on surrounding land around any new villages/towns.
3.9 Figure 23 of the Spatial Options document provides a Sustainability Appraisal of the various Options and this illustrates the balance that Option 2 provides, albeit it is noted that Option 4 scores best.
However, due to its mix of strategies for the delivery of development we would note a concern that it would pose significant complexities in implementing. In order to achieve the development required the full mix of strategies would be required, and if one were to fail or be delayed (as is a real risk with new villages/towns), a shortfall in housing or employment space could result, putting the Council’s position at risk.
Question 56a. Do you agree with our vision for Rayleigh? Is there anything you feel is missing?
3.10 We support the vision for Rayleigh. It is and should remain the only Tier 1 settlement given its existing
population mass, infrastructure/facilities provision and ability to accommodate significant growth relative to other settlements. The growth and expansion of Rayleigh with urban extensions would generate a sizeable portion of the housing quota required to respond to the identified housing need. Through the development of the majority of those sites submitted for consideration around the edges of Rayleigh, this focal settlement could alleviate pressures on more rural settings and larger swathes of
Green Belt throughout the rest of the district.
Questions 56b, 56c, 56d and 56e.
3.11 It is submitted that land at Call for Sites references CFS044 and CFS256 would offer an opportunity to
contribute to identified housing need delivery in a Green Belt location that could maintain the five purposes of Green Belt and in a location that has reduced landscape quality but is also well screened from surrounding areas. The attached initial Scoping Landscape Statement and Transport Planning Technical Note support that proposal.
3.12 The Council have carried out an initial assessment of these sites, as below.

[SEE DOCUMENT FOR IMAGE]

3.13 Whilst the appraisals above highlight the impact upon Green Belt, as discussed it is submitted that most
virgin sites put forward will impact upon that designation. It is considered that a sequential assessment
of the districts Green Belt would be appropriate in this regard and could highlight those sites that would
have a lesser visual impact and still maintain the purposes of Green Belt as best possible. The above
sites are expected to respond positively in both regards. The accompanying Scoping Landscape Statement concludes thus;
The landscape is subdivided into paddocks and is not of the highest visual quality, but the structure is strong and there are valued elements within it. The site is well contained by woodland and hedgerows, which should be used to inform design work for any forthcoming development proposal. Development of the site would take place within the current Green Belt designation / boundary, but the impact of development upon the openness of the Green Belt would be limited, due to the site's location adjacent to the existing urban area, its location within an enclave of landscape defined by the urban area and the A127, and the fact that the site's character is already enclosed, offering few publicly
accessible viewpoints.
Development of the site would not bring about coalescence of settlement, due to the strong landscape
barrier represented by the A127 itself, and the extensive Pound Wood Nature Reserve to the south of it,
separating the site from Daws Heath. Should the site be brought forward for development, design work should be informed by a full understanding of local landscape and visual character. The enclosed and compartmentalised character of the site should be retained and used as a constraint for design.
3.14 The Sustainability Appraisal also scores the sites low on ‘Existing site access’. However, the
accompanying Transport Planning Technical Note identifies 3no. possible accesses to the site, two of
which would be new accesses. It comments thus;
A number of options have been identified as having good potential for providing vehicle access to the site to unlock its development potential and deliver between 200 and 300 residential dwellings as part of the new Rochford Local Plan.
Providing a sustainable transport link from the site to the north is considered important to unlock the full sustainable development potential of the site as there are a number of local facilities and services on this section of A1015 Eastwood Road including bus stops.
3.15 It is submitted that in other key criteria the sites score well in the Sustainability Appraisal and in
combination would provide a high scoring option as a residential/housing allocation (including market
and affordable).
3.16 It is submitted that generally the area of these sites is well suited to accommodating a moderate
amount of new development. It is well enclosed by existing built form with the edge of Rayleigh to the
immediate north and the A127 to the immediate south. As such it would not lead to an interruption of
open land and countryside to the detriment of the landscape and quality of Green Belt. Furthermore,
this area scores well in terms of its Walking Completeness Score, in particular the two sites identified,
which are adjacent to land scoring of 8-10.
3.17 In combination with other similarly sized sites in this location to the south east of Rayleigh, a good level
of housing land supply could be achieved across numerous parcels (each able to provide in the region
100 to 400 dwellings). This would not necessitate significant new infrastructure but rather upgrades to
existing. Furthermore, the delivery of this volume of dwellings across several parcels would allow for
the retention of important green spaces and structural planting in between, which could serve to
maintain the green character of this urban/rural fringe and complement the Green Belt beyond.
3.18 We Support the allocation of Open Space and Local Wildlife Sites to the east of Rayleigh. It is
submitted that development on or adjacent to these protected sites could negatively impact upon
them, through increased light/air/noise pollution and walker/visitors (in the case of the wildlife sites).
There is an added logic in retaining these sites as open space and wildlife sites (for their intrinsic value)
as they could double as Green Belt.

1. INTRODUCTION
1.1 Rochford District Council is seeking feedback from interested parties on its identified ‘Options’ in the
New Local Plan: Spatial Options document.
1.2 Lee Evans Planning have been instructed to make representations on behalf of Ms Suzanne Redwood,
Mr Roger Lambourne and Mr Colin Humphries.
1.3 Section 2 sets out relevant extant Planning Policy considerations.
1.4 Section 3 reviews and comments on the Spatial Options document, including providing responses to
Questions outlined in the Consultation.

2. CURRENT POLICY POSITION
National Planning Policy Framework
2.1 The National Planning Policy Framework sets out the meaning and role of sustainable development and how planning can help to achieve it. At a very high level, the objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs.
2.2 A rising population and longer life expectancy requires growth and an increase in the volume and
choice of housing. The NPPF identifies the need to complement this growth with high standards of
design and to protect our built, natural and historic environments. The NPPF also highlights the
fundamental role that sustainable development plays in the plan-making and decision making process.
So that sustainable development is pursued in a positive way, at the heart of the Framework is a presumption in favour of sustainable development
2.3 The NPPF serves to provide a framework around which the community and the councils can produce
the local and neighbourhood plans, which reflect the needs and priorities of the community.
The National Planning Policy Framework must be taken into account in preparing the development plan, and is a material consideration in planning decisions.
2.5 Paragraph 8 of the NPPF reiterates the role of the planning system and the contribution it must make to realising sustainable development. Sustainable development has three dimensions to it; economic,
social and environmental.
• an economic objective – to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and
coordinating the provision of infrastructure;
• a social objective – to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering well-designed, beautiful and safe places, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being; and
• an environmental objective – to protect and enhance our natural, built and historic environment; including making effective use of land, improving biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate
change, including moving to a low carbon economy.
2.6 The NPPF considers in further detail the need to protect and improve the quality of the built, natural and historic environment. One aspect of this aim is to widen the choice of quality homes. This can be achieved through the plan-making process, as discussed in paragraph 11.
Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that:
a) all plans should promote a sustainable pattern of development that seeks to: meet the development
needs of their area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects;
b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:
i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or
ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when
assessed against the policies in this Framework taken as a whole.
2.7 Paragraph 60 notes the need to boost the supply of homes through land allocation. To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay.
2.8 Paragraph 61 outlines the approach to determining housing need. The New Local Plan; Spatial Options
document is unclear on the degree to which the duty to cooperate has been explored with neighbouring areas, suggesting that at present the assumption should be made that all identified housing need must be delivered within the district.
To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.
2.9 Each year the local planning authority will identify their supply of specific deliverable sites to provide the next five years of housing with an additional 5% buffer. This will allow for both choice and competition in the market. Developable sites that can accommodate for years 6-10 of the plan period and beyond will also be identified.
2.10 A 10% buffer should be provided “where the local planning authority wishes to demonstrate a five year
supply of deliverable sites through an annual position statement or recently adopted plan, to account for any fluctuations in the market during that year”.
2.11 A 20% buffer should be provided “where there has been significant under delivery of housing over the
previous three years, to improve the prospect of achieving the planned supply”. The NPPG elaborates
by stating that “A 20% buffer will apply to a local planning authority’s five-year land supply if housing delivery falls below 85%”.
2.12 If a five year supply of deliverable housing cannot be demonstrated policies relating to the supply of housing should not be considered to be up-to-date. All housing applications should be considered on the basis of a presumption in favour of sustainable development as has been discussed above. The most recent Authority Monitoring Report (draft 2019-2020), suggests that there exists a district housing need of 1,800 homes over a five year period (equating to 360 homes per year) and that the Council could at that time illustrate a 6.32 year housing land supply at a 5% buffer level, and 5.53 year supply at the 20% buffer, albeit it is noted that this was only draft and requires updating for the 2020-2021 period. The current supply is unknown but the Spatial Options document notes that the need for 360 homes per
year over the course of the Plan (20 years), equating to 7,200 homes total, remains. This figure does not include for assisting other districts in the duty to cooperate or any 5/20% buffer, so could well be higher. Notwithstanding this, there is a clear need to increase the allocation of housing land in the new Local Plan to illustrate the potential for 7,200 homes to be delivered.
2.13 Paragraph 73 highlights the opportunity for larger scale development and the benefits of this approach
in achieving the necessary supply of housing. It is possible that new settlements or extensions to
existing settlements can provide a route to sustainable development.
The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities (including a genuine choice of transport modes).
2.14 Paragraph 23 notes that Local Plans should plan positively for development by allocating sites for
development and identify land where development would be inappropriate due to its environmental or historic significance.
Broad locations for development should be indicated on a key diagram, and landuse designations and allocations identified on a policies map. Strategic policies should provide a clear strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period, in line with the presumption in favour of sustainable development. This should include planning or and allocating sufficient sites to deliver the strategic priorities of the area
2.15 Paragraph 138 of the NPPF refers to the purposes of the Green Belt;
Green Belt serves five purposes:
a) to check the unrestricted sprawl of large built-up areas;
b) to prevent neighbouring towns merging into one another;
c) to assist in safeguarding the countryside from encroachment;
d) to preserve the setting and special character of historic towns; and
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
2.16 Local Plans will be examined by an independent inspector before they are adopted. To be considered
ready for adoption they will need to be shown to be ‘sound’, as per paragraph 35 of the NPPF;
Local plans and spatial development strategies are examined to assess whether they have been
prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are
‘sound’ if they are:
a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
c) Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant. Rochford District Core Strategy and the Allocations Plan
2.17 The key strategic documents in the local development plan are the adopted Core Strategy 2011 and the Allocations Plan 2014. These are both dated documents and would be considered out of date where
the content conflicts with NPPF policy. Nonetheless, they provide a useful basis against which to subsequently consider the options in the New Local Plan consultation.
2.18 The following exerts are of interest;
District
2.41 “Failure to provide affordable housing that meets the needs of the District’s residents may lead to
continued out-migration, to the detriment of the vitality of local communities.” (p31)
Rayleigh
“The largest settlement is Rayleigh which, in 2001, was home to 30,196 people (38% of the District’s
residents at that time).” (p28)
Housing Development
2.39 “As well as directing housing growth to areas of need/demand, and away from unsustainable
locations subject to constraints, the Council must consider the relationship of housing growth to areas
of employment growth.” (p30)
Vision – Medium/Long Term “A range of high-quality, sustainable new dwellings that meet the needs
of local people of all social groups are in place and integrated into communities. The vast majority of
the District’s Green Belt remains undeveloped. New infrastructure has accompanied new residential
development, meeting the need of local communities.” (p41)
Policy H1 – the efficient use of land for housing
“The remaining housing requirement that cannot be delivered through the redevelopment of appropriate previously developed land will be met through extensions to the residential envelopes of existing settlements as outlined in Policy H2.” (p45)
The Green Belt
Housing Objective “Prioritise the redevelopment of appropriate brownfield sites for housing, to minimise the release of Green Belt land for development” (p41).
“In order to fulfil the requirements of the East of England Plan and to meet the housing need of the District, the Council is required to allocate additional land for residential development, including land, which is currently allocated as Green Belt, due to the limited supply” (p45).
“it must be also mindful of the need to maintain Green Belt as far as possible.” (p46)
2.19 The extant Core Strategy outlines a strong protection of the Green Belt, as per national policy. However, this was predicated on an old housing need and supply, which is now out of line with current demand
and what can be achieved through existing permissions, allocations, brownfield sites and windfall forecasts. Rayleigh is considered a focal settlement and one that has both a sizeable population already and the infrastructure to service those residents.
2.20 Notwithstanding the above, the Council recognised the need to review the designation of the Green Belt in the face of the relatively low housing need at the time the Core Strategy was drafted. It states;
The Council will continue to support the principles of restricting development in the Green Belt, as set out in PPG2, and will preserve the character and openness of the Green Belt. However, a small proportion of the District’s Green Belt will have to have its designation reviewed to allow the development of additional housing and business premises, taking account of the very limited
opportunities to accommodate further development within existing settlements.
2.21 This position regarding housing need and lack of land supply (before moving onto Green Belt land), will
be felt more acutely during the drafting of this new Local Plan.

3. NEW LOCAL PLAN: SPATIAL OPTIONS QUESTIONS
3.1 It is noted that in its introductory section the Spatial Options document considers the need to “coordinate the delivery of much needed housing”. It also states that;

“Rochford should consider every opportunity to meet its own housing needs within its own authority
area, with a focus on genuinely affordable housing that meets genuinely local needs”
3.2 Given the extent of Green Belt in this part of South East Essex, it is considered likely that as in Rochford,
surrounding districts will find it difficult to deliver their full quota of required housing land supply within
existing settlements and on brownfield land, i.e. there will be a need to use Green Belt. To this end it is
submitted that they will be unable to offer assistance to Rochford in providing surplus land to accommodate housing delivery. We support the Spatial Options document in the above assertion.
3.3 This will necessitate a review of Green Belt designation to a greater extent than that previously carried out with the adopted Core Strategy. As noted above, Green Belt serves 5 purposes; “to check the
unrestricted sprawl of large built-up areas, to prevent neighbouring towns merging into one another, to
assist in safeguarding the countryside from encroachment, to preserve the setting and special character of historic towns and to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.” It is submitted that where these matters are less acutely felt, and in those areas of lesser
landscape quality, new housing land allocations could be proposed within the currently designated Green Belt, to assist with achieving the necessary housing land supply. The Core Strategy acknowledges this approach;
The term ‘Green Belt’ refers to a planning designation and is not necessarily a description of quality of
the land. Land designated as Green Belt can include, primarily for historical reasons, developed land and
brownfield sites. As such, whilst it is considered that all land currently designated as Green Belt helps achieve the five green belt purposes as set out in the NPPF to at least a degree, some green belt land is less worthy of continued protection.
3.4 This is acknowledged in the New Local Plan: Spatial Options document, which considers 4no. spatial
options for delivery of necessary development and infrastructure. All but Option 1 would necessitate
the use of Green Belt.
Question 5. Do you agree with the settlement hierarchy presented? If not, what changes do you think
are required?
3.6 We support the settlement hierarchy presented. This focuses development at the most appropriate
settlements in the order of their ability to support new development. Rayleigh benefits from a strong existing resident mass and thus has a viability for growth and expansion of businesses and communities. We would submit that the majority of new development, and residential site allocations, should be around Rayleigh.
Question 6. Which of the identified strategy options do you consider should be taken forward in the Plan?
3.7 We support Strategy Option 2 and in particular Option 2a. This option provides a balanced response to the housing need of 7,200 – 10,800 dwellings (delivering between 8,700 to 10,700 dwellings), the necessary mass to support a good level of new infrastructure and facilities, and the need to minimise as much as possible the release of Green Belt for development.
3.8 Option 1 would not deliver the required housing land necessary to respond to the identified housing
need over the course of the Plan, and as discussed, it is considered unlikely that other surrounding districts would be able to assist with additional land. Option 3 would necessitate a significant release of Green Belt and would have a significant impact on the character of the surrounding Green Belt due to the size of a new villages/towns. As with to Option 3, Option 4 would require a sizeable release of Green Belt and significant impact on surrounding land around any new villages/towns.
3.9 Figure 23 of the Spatial Options document provides a Sustainability Appraisal of the various Options and this illustrates the balance that Option 2 provides, albeit it is noted that Option 4 scores best.
However, due to its mix of strategies for the delivery of development we would note a concern that it would pose significant complexities in implementing. In order to achieve the development required the full mix of strategies would be required, and if one were to fail or be delayed (as is a real risk with new villages/towns), a shortfall in housing or employment space could result, putting the Council’s position at risk.
Question 56a. Do you agree with our vision for Rayleigh? Is there anything you feel is missing?
3.10 We support the vision for Rayleigh. It is and should remain the only Tier 1 settlement given its existing
population mass, infrastructure/facilities provision and ability to accommodate significant growth relative to other settlements. The growth and expansion of Rayleigh with urban extensions would generate a sizeable portion of the housing quota required to respond to the identified housing need. Through the development of the majority of those sites submitted for consideration around the edges of Rayleigh, this focal settlement could alleviate pressures on more rural settings and larger swathes of
Green Belt throughout the rest of the district.
Questions 56b, 56c, 56d and 56e.
3.11 It is submitted that land at Call for Sites references CFS044 and CFS256 would offer an opportunity to
contribute to identified housing need delivery in a Green Belt location that could maintain the five purposes of Green Belt and in a location that has reduced landscape quality but is also well screened from surrounding areas. The attached initial Scoping Landscape Statement and Transport Planning Technical Note support that proposal.
3.12 The Council have carried out an initial assessment of these sites, as below.

[SEE DOCUMENT FOR IMAGE]

3.13 Whilst the appraisals above highlight the impact upon Green Belt, as discussed it is submitted that most
virgin sites put forward will impact upon that designation. It is considered that a sequential assessment
of the districts Green Belt would be appropriate in this regard and could highlight those sites that would
have a lesser visual impact and still maintain the purposes of Green Belt as best possible. The above
sites are expected to respond positively in both regards. The accompanying Scoping Landscape Statement concludes thus;
The landscape is subdivided into paddocks and is not of the highest visual quality, but the structure is strong and there are valued elements within it. The site is well contained by woodland and hedgerows, which should be used to inform design work for any forthcoming development proposal. Development of the site would take place within the current Green Belt designation / boundary, but the impact of development upon the openness of the Green Belt would be limited, due to the site's location adjacent to the existing urban area, its location within an enclave of landscape defined by the urban area and the A127, and the fact that the site's character is already enclosed, offering few publicly
accessible viewpoints.
Development of the site would not bring about coalescence of settlement, due to the strong landscape
barrier represented by the A127 itself, and the extensive Pound Wood Nature Reserve to the south of it,
separating the site from Daws Heath. Should the site be brought forward for development, design work should be informed by a full understanding of local landscape and visual character. The enclosed and compartmentalised character of the site should be retained and used as a constraint for design.
3.14 The Sustainability Appraisal also scores the sites low on ‘Existing site access’. However, the
accompanying Transport Planning Technical Note identifies 3no. possible accesses to the site, two of
which would be new accesses. It comments thus;
A number of options have been identified as having good potential for providing vehicle access to the site to unlock its development potential and deliver between 200 and 300 residential dwellings as part of the new Rochford Local Plan.
Providing a sustainable transport link from the site to the north is considered important to unlock the full sustainable development potential of the site as there are a number of local facilities and services on this section of A1015 Eastwood Road including bus stops.
3.15 It is submitted that in other key criteria the sites score well in the Sustainability Appraisal and in
combination would provide a high scoring option as a residential/housing allocation (including market
and affordable).
3.16 It is submitted that generally the area of these sites is well suited to accommodating a moderate
amount of new development. It is well enclosed by existing built form with the edge of Rayleigh to the
immediate north and the A127 to the immediate south. As such it would not lead to an interruption of
open land and countryside to the detriment of the landscape and quality of Green Belt. Furthermore,
this area scores well in terms of its Walking Completeness Score, in particular the two sites identified,
which are adjacent to land scoring of 8-10.
3.17 In combination with other similarly sized sites in this location to the south east of Rayleigh, a good level
of housing land supply could be achieved across numerous parcels (each able to provide in the region
100 to 400 dwellings). This would not necessitate significant new infrastructure but rather upgrades to
existing. Furthermore, the delivery of this volume of dwellings across several parcels would allow for
the retention of important green spaces and structural planting in between, which could serve to
maintain the green character of this urban/rural fringe and complement the Green Belt beyond.
3.18 We Support the allocation of Open Space and Local Wildlife Sites to the east of Rayleigh. It is
submitted that development on or adjacent to these protected sites could negatively impact upon
them, through increased light/air/noise pollution and walker/visitors (in the case of the wildlife sites).
There is an added logic in retaining these sites as open space and wildlife sites (for their intrinsic value)
as they could double as Green Belt.

1. INTRODUCTION
1.1 Rochford District Council is seeking feedback from interested parties on its identified ‘Options’ in the
New Local Plan: Spatial Options document.
1.2 Lee Evans Planning have been instructed to make representations on behalf of Ms Suzanne Redwood,
Mr Roger Lambourne and Mr Colin Humphries.
1.3 Section 2 sets out relevant extant Planning Policy considerations.
1.4 Section 3 reviews and comments on the Spatial Options document, including providing responses to
Questions outlined in the Consultation.

2. CURRENT POLICY POSITION
National Planning Policy Framework
2.1 The National Planning Policy Framework sets out the meaning and role of sustainable development and how planning can help to achieve it. At a very high level, the objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs.
2.2 A rising population and longer life expectancy requires growth and an increase in the volume and
choice of housing. The NPPF identifies the need to complement this growth with high standards of
design and to protect our built, natural and historic environments. The NPPF also highlights the
fundamental role that sustainable development plays in the plan-making and decision making process.
So that sustainable development is pursued in a positive way, at the heart of the Framework is a presumption in favour of sustainable development
2.3 The NPPF serves to provide a framework around which the community and the councils can produce
the local and neighbourhood plans, which reflect the needs and priorities of the community.
The National Planning Policy Framework must be taken into account in preparing the development plan, and is a material consideration in planning decisions.
2.5 Paragraph 8 of the NPPF reiterates the role of the planning system and the contribution it must make to realising sustainable development. Sustainable development has three dimensions to it; economic,
social and environmental.
• an economic objective – to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and
coordinating the provision of infrastructure;
• a social objective – to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering well-designed, beautiful and safe places, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being; and
• an environmental objective – to protect and enhance our natural, built and historic environment; including making effective use of land, improving biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate
change, including moving to a low carbon economy.
2.6 The NPPF considers in further detail the need to protect and improve the quality of the built, natural and historic environment. One aspect of this aim is to widen the choice of quality homes. This can be achieved through the plan-making process, as discussed in paragraph 11.
Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that:
a) all plans should promote a sustainable pattern of development that seeks to: meet the development
needs of their area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects;
b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:
i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or
ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when
assessed against the policies in this Framework taken as a whole.
2.7 Paragraph 60 notes the need to boost the supply of homes through land allocation. To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay.
2.8 Paragraph 61 outlines the approach to determining housing need. The New Local Plan; Spatial Options
document is unclear on the degree to which the duty to cooperate has been explored with neighbouring areas, suggesting that at present the assumption should be made that all identified housing need must be delivered within the district.
To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.
2.9 Each year the local planning authority will identify their supply of specific deliverable sites to provide the next five years of housing with an additional 5% buffer. This will allow for both choice and competition in the market. Developable sites that can accommodate for years 6-10 of the plan period and beyond will also be identified.
2.10 A 10% buffer should be provided “where the local planning authority wishes to demonstrate a five year
supply of deliverable sites through an annual position statement or recently adopted plan, to account for any fluctuations in the market during that year”.
2.11 A 20% buffer should be provided “where there has been significant under delivery of housing over the
previous three years, to improve the prospect of achieving the planned supply”. The NPPG elaborates
by stating that “A 20% buffer will apply to a local planning authority’s five-year land supply if housing delivery falls below 85%”.
2.12 If a five year supply of deliverable housing cannot be demonstrated policies relating to the supply of housing should not be considered to be up-to-date. All housing applications should be considered on the basis of a presumption in favour of sustainable development as has been discussed above. The most recent Authority Monitoring Report (draft 2019-2020), suggests that there exists a district housing need of 1,800 homes over a five year period (equating to 360 homes per year) and that the Council could at that time illustrate a 6.32 year housing land supply at a 5% buffer level, and 5.53 year supply at the 20% buffer, albeit it is noted that this was only draft and requires updating for the 2020-2021 period. The current supply is unknown but the Spatial Options document notes that the need for 360 homes per
year over the course of the Plan (20 years), equating to 7,200 homes total, remains. This figure does not include for assisting other districts in the duty to cooperate or any 5/20% buffer, so could well be higher. Notwithstanding this, there is a clear need to increase the allocation of housing land in the new Local Plan to illustrate the potential for 7,200 homes to be delivered.
2.13 Paragraph 73 highlights the opportunity for larger scale development and the benefits of this approach
in achieving the necessary supply of housing. It is possible that new settlements or extensions to
existing settlements can provide a route to sustainable development.
The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities (including a genuine choice of transport modes).
2.14 Paragraph 23 notes that Local Plans should plan positively for development by allocating sites for
development and identify land where development would be inappropriate due to its environmental or historic significance.
Broad locations for development should be indicated on a key diagram, and landuse designations and allocations identified on a policies map. Strategic policies should provide a clear strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period, in line with the presumption in favour of sustainable development. This should include planning or and allocating sufficient sites to deliver the strategic priorities of the area
2.15 Paragraph 138 of the NPPF refers to the purposes of the Green Belt;
Green Belt serves five purposes:
a) to check the unrestricted sprawl of large built-up areas;
b) to prevent neighbouring towns merging into one another;
c) to assist in safeguarding the countryside from encroachment;
d) to preserve the setting and special character of historic towns; and
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
2.16 Local Plans will be examined by an independent inspector before they are adopted. To be considered
ready for adoption they will need to be shown to be ‘sound’, as per paragraph 35 of the NPPF;
Local plans and spatial development strategies are examined to assess whether they have been
prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are
‘sound’ if they are:
a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
c) Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant. Rochford District Core Strategy and the Allocations Plan
2.17 The key strategic documents in the local development plan are the adopted Core Strategy 2011 and the Allocations Plan 2014. These are both dated documents and would be considered out of date where
the content conflicts with NPPF policy. Nonetheless, they provide a useful basis against which to subsequently consider the options in the New Local Plan consultation.
2.18 The following exerts are of interest;
District
2.41 “Failure to provide affordable housing that meets the needs of the District’s residents may lead to
continued out-migration, to the detriment of the vitality of local communities.” (p31)
Rayleigh
“The largest settlement is Rayleigh which, in 2001, was home to 30,196 people (38% of the District’s
residents at that time).” (p28)
Housing Development
2.39 “As well as directing housing growth to areas of need/demand, and away from unsustainable
locations subject to constraints, the Council must consider the relationship of housing growth to areas
of employment growth.” (p30)
Vision – Medium/Long Term “A range of high-quality, sustainable new dwellings that meet the needs
of local people of all social groups are in place and integrated into communities. The vast majority of
the District’s Green Belt remains undeveloped. New infrastructure has accompanied new residential
development, meeting the need of local communities.” (p41)
Policy H1 – the efficient use of land for housing
“The remaining housing requirement that cannot be delivered through the redevelopment of appropriate previously developed land will be met through extensions to the residential envelopes of existing settlements as outlined in Policy H2.” (p45)
The Green Belt
Housing Objective “Prioritise the redevelopment of appropriate brownfield sites for housing, to minimise the release of Green Belt land for development” (p41).
“In order to fulfil the requirements of the East of England Plan and to meet the housing need of the District, the Council is required to allocate additional land for residential development, including land, which is currently allocated as Green Belt, due to the limited supply” (p45).
“it must be also mindful of the need to maintain Green Belt as far as possible.” (p46)
2.19 The extant Core Strategy outlines a strong protection of the Green Belt, as per national policy. However, this was predicated on an old housing need and supply, which is now out of line with current demand
and what can be achieved through existing permissions, allocations, brownfield sites and windfall forecasts. Rayleigh is considered a focal settlement and one that has both a sizeable population already and the infrastructure to service those residents.
2.20 Notwithstanding the above, the Council recognised the need to review the designation of the Green Belt in the face of the relatively low housing need at the time the Core Strategy was drafted. It states;
The Council will continue to support the principles of restricting development in the Green Belt, as set out in PPG2, and will preserve the character and openness of the Green Belt. However, a small proportion of the District’s Green Belt will have to have its designation reviewed to allow the development of additional housing and business premises, taking account of the very limited
opportunities to accommodate further development within existing settlements.
2.21 This position regarding housing need and lack of land supply (before moving onto Green Belt land), will
be felt more acutely during the drafting of this new Local Plan.

3. NEW LOCAL PLAN: SPATIAL OPTIONS QUESTIONS
3.1 It is noted that in its introductory section the Spatial Options document considers the need to “coordinate the delivery of much needed housing”. It also states that;

“Rochford should consider every opportunity to meet its own housing needs within its own authority
area, with a focus on genuinely affordable housing that meets genuinely local needs”
3.2 Given the extent of Green Belt in this part of South East Essex, it is considered likely that as in Rochford,
surrounding districts will find it difficult to deliver their full quota of required housing land supply within
existing settlements and on brownfield land, i.e. there will be a need to use Green Belt. To this end it is
submitted that they will be unable to offer assistance to Rochford in providing surplus land to accommodate housing delivery. We support the Spatial Options document in the above assertion.
3.3 This will necessitate a review of Green Belt designation to a greater extent than that previously carried out with the adopted Core Strategy. As noted above, Green Belt serves 5 purposes; “to check the
unrestricted sprawl of large built-up areas, to prevent neighbouring towns merging into one another, to
assist in safeguarding the countryside from encroachment, to preserve the setting and special character of historic towns and to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.” It is submitted that where these matters are less acutely felt, and in those areas of lesser
landscape quality, new housing land allocations could be proposed within the currently designated Green Belt, to assist with achieving the necessary housing land supply. The Core Strategy acknowledges this approach;
The term ‘Green Belt’ refers to a planning designation and is not necessarily a description of quality of
the land. Land designated as Green Belt can include, primarily for historical reasons, developed land and
brownfield sites. As such, whilst it is considered that all land currently designated as Green Belt helps achieve the five green belt purposes as set out in the NPPF to at least a degree, some green belt land is less worthy of continued protection.
3.4 This is acknowledged in the New Local Plan: Spatial Options document, which considers 4no. spatial
options for delivery of necessary development and infrastructure. All but Option 1 would necessitate
the use of Green Belt.
Question 5. Do you agree with the settlement hierarchy presented? If not, what changes do you think
are required?
3.6 We support the settlement hierarchy presented. This focuses development at the most appropriate
settlements in the order of their ability to support new development. Rayleigh benefits from a strong existing resident mass and thus has a viability for growth and expansion of businesses and communities. We would submit that the majority of new development, and residential site allocations, should be around Rayleigh.
Question 6. Which of the identified strategy options do you consider should be taken forward in the Plan?
3.7 We support Strategy Option 2 and in particular Option 2a. This option provides a balanced response to the housing need of 7,200 – 10,800 dwellings (delivering between 8,700 to 10,700 dwellings), the necessary mass to support a good level of new infrastructure and facilities, and the need to minimise as much as possible the release of Green Belt for development.
3.8 Option 1 would not deliver the required housing land necessary to respond to the identified housing
need over the course of the Plan, and as discussed, it is considered unlikely that other surrounding districts would be able to assist with additional land. Option 3 would necessitate a significant release of Green Belt and would have a significant impact on the character of the surrounding Green Belt due to the size of a new villages/towns. As with to Option 3, Option 4 would require a sizeable release of Green Belt and significant impact on surrounding land around any new villages/towns.
3.9 Figure 23 of the Spatial Options document provides a Sustainability Appraisal of the various Options and this illustrates the balance that Option 2 provides, albeit it is noted that Option 4 scores best.
However, due to its mix of strategies for the delivery of development we would note a concern that it would pose significant complexities in implementing. In order to achieve the development required the full mix of strategies would be required, and if one were to fail or be delayed (as is a real risk with new villages/towns), a shortfall in housing or employment space could result, putting the Council’s position at risk.
Question 56a. Do you agree with our vision for Rayleigh? Is there anything you feel is missing?
3.10 We support the vision for Rayleigh. It is and should remain the only Tier 1 settlement given its existing
population mass, infrastructure/facilities provision and ability to accommodate significant growth relative to other settlements. The growth and expansion of Rayleigh with urban extensions would generate a sizeable portion of the housing quota required to respond to the identified housing need. Through the development of the majority of those sites submitted for consideration around the edges of Rayleigh, this focal settlement could alleviate pressures on more rural settings and larger swathes of
Green Belt throughout the rest of the district.
Questions 56b, 56c, 56d and 56e.
3.11 It is submitted that land at Call for Sites references CFS044 and CFS256 would offer an opportunity to
contribute to identified housing need delivery in a Green Belt location that could maintain the five purposes of Green Belt and in a location that has reduced landscape quality but is also well screened from surrounding areas. The attached initial Scoping Landscape Statement and Transport Planning Technical Note support that proposal.
3.12 The Council have carried out an initial assessment of these sites, as below.

[SEE DOCUMENT FOR IMAGE]

3.13 Whilst the appraisals above highlight the impact upon Green Belt, as discussed it is submitted that most
virgin sites put forward will impact upon that designation. It is considered that a sequential assessment
of the districts Green Belt would be appropriate in this regard and could highlight those sites that would
have a lesser visual impact and still maintain the purposes of Green Belt as best possible. The above
sites are expected to respond positively in both regards. The accompanying Scoping Landscape Statement concludes thus;
The landscape is subdivided into paddocks and is not of the highest visual quality, but the structure is strong and there are valued elements within it. The site is well contained by woodland and hedgerows, which should be used to inform design work for any forthcoming development proposal. Development of the site would take place within the current Green Belt designation / boundary, but the impact of development upon the openness of the Green Belt would be limited, due to the site's location adjacent to the existing urban area, its location within an enclave of landscape defined by the urban area and the A127, and the fact that the site's character is already enclosed, offering few publicly
accessible viewpoints.
Development of the site would not bring about coalescence of settlement, due to the strong landscape
barrier represented by the A127 itself, and the extensive Pound Wood Nature Reserve to the south of it,
separating the site from Daws Heath. Should the site be brought forward for development, design work should be informed by a full understanding of local landscape and visual character. The enclosed and compartmentalised character of the site should be retained and used as a constraint for design.
3.14 The Sustainability Appraisal also scores the sites low on ‘Existing site access’. However, the
accompanying Transport Planning Technical Note identifies 3no. possible accesses to the site, two of
which would be new accesses. It comments thus;
A number of options have been identified as having good potential for providing vehicle access to the site to unlock its development potential and deliver between 200 and 300 residential dwellings as part of the new Rochford Local Plan.
Providing a sustainable transport link from the site to the north is considered important to unlock the full sustainable development potential of the site as there are a number of local facilities and services on this section of A1015 Eastwood Road including bus stops.
3.15 It is submitted that in other key criteria the sites score well in the Sustainability Appraisal and in
combination would provide a high scoring option as a residential/housing allocation (including market
and affordable).
3.16 It is submitted that generally the area of these sites is well suited to accommodating a moderate
amount of new development. It is well enclosed by existing built form with the edge of Rayleigh to the
immediate north and the A127 to the immediate south. As such it would not lead to an interruption of
open land and countryside to the detriment of the landscape and quality of Green Belt. Furthermore,
this area scores well in terms of its Walking Completeness Score, in particular the two sites identified,
which are adjacent to land scoring of 8-10.
3.17 In combination with other similarly sized sites in this location to the south east of Rayleigh, a good level
of housing land supply could be achieved across numerous parcels (each able to provide in the region
100 to 400 dwellings). This would not necessitate significant new infrastructure but rather upgrades to
existing. Furthermore, the delivery of this volume of dwellings across several parcels would allow for
the retention of important green spaces and structural planting in between, which could serve to
maintain the green character of this urban/rural fringe and complement the Green Belt beyond.
3.18 We Support the allocation of Open Space and Local Wildlife Sites to the east of Rayleigh. It is
submitted that development on or adjacent to these protected sites could negatively impact upon
them, through increased light/air/noise pollution and walker/visitors (in the case of the wildlife sites).
There is an added logic in retaining these sites as open space and wildlife sites (for their intrinsic value)
as they could double as Green Belt.

1. INTRODUCTION
1.1 Rochford District Council is seeking feedback from interested parties on its identified ‘Options’ in the
New Local Plan: Spatial Options document.
1.2 Lee Evans Planning have been instructed to make representations on behalf of Ms Suzanne Redwood,
Mr Roger Lambourne and Mr Colin Humphries.
1.3 Section 2 sets out relevant extant Planning Policy considerations.
1.4 Section 3 reviews and comments on the Spatial Options document, including providing responses to
Questions outlined in the Consultation.

2. CURRENT POLICY POSITION
National Planning Policy Framework
2.1 The National Planning Policy Framework sets out the meaning and role of sustainable development and how planning can help to achieve it. At a very high level, the objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs.
2.2 A rising population and longer life expectancy requires growth and an increase in the volume and
choice of housing. The NPPF identifies the need to complement this growth with high standards of
design and to protect our built, natural and historic environments. The NPPF also highlights the
fundamental role that sustainable development plays in the plan-making and decision making process.
So that sustainable development is pursued in a positive way, at the heart of the Framework is a presumption in favour of sustainable development
2.3 The NPPF serves to provide a framework around which the community and the councils can produce
the local and neighbourhood plans, which reflect the needs and priorities of the community.
The National Planning Policy Framework must be taken into account in preparing the development plan, and is a material consideration in planning decisions.
2.5 Paragraph 8 of the NPPF reiterates the role of the planning system and the contribution it must make to realising sustainable development. Sustainable development has three dimensions to it; economic,
social and environmental.
• an economic objective – to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and
coordinating the provision of infrastructure;
• a social objective – to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering well-designed, beautiful and safe places, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being; and
• an environmental objective – to protect and enhance our natural, built and historic environment; including making effective use of land, improving biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate
change, including moving to a low carbon economy.
2.6 The NPPF considers in further detail the need to protect and improve the quality of the built, natural and historic environment. One aspect of this aim is to widen the choice of quality homes. This can be achieved through the plan-making process, as discussed in paragraph 11.
Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that:
a) all plans should promote a sustainable pattern of development that seeks to: meet the development
needs of their area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects;
b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:
i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or
ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when
assessed against the policies in this Framework taken as a whole.
2.7 Paragraph 60 notes the need to boost the supply of homes through land allocation. To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay.
2.8 Paragraph 61 outlines the approach to determining housing need. The New Local Plan; Spatial Options
document is unclear on the degree to which the duty to cooperate has been explored with neighbouring areas, suggesting that at present the assumption should be made that all identified housing need must be delivered within the district.
To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.
2.9 Each year the local planning authority will identify their supply of specific deliverable sites to provide the next five years of housing with an additional 5% buffer. This will allow for both choice and competition in the market. Developable sites that can accommodate for years 6-10 of the plan period and beyond will also be identified.
2.10 A 10% buffer should be provided “where the local planning authority wishes to demonstrate a five year
supply of deliverable sites through an annual position statement or recently adopted plan, to account for any fluctuations in the market during that year”.
2.11 A 20% buffer should be provided “where there has been significant under delivery of housing over the
previous three years, to improve the prospect of achieving the planned supply”. The NPPG elaborates
by stating that “A 20% buffer will apply to a local planning authority’s five-year land supply if housing delivery falls below 85%”.
2.12 If a five year supply of deliverable housing cannot be demonstrated policies relating to the supply of housing should not be considered to be up-to-date. All housing applications should be considered on the basis of a presumption in favour of sustainable development as has been discussed above. The most recent Authority Monitoring Report (draft 2019-2020), suggests that there exists a district housing need of 1,800 homes over a five year period (equating to 360 homes per year) and that the Council could at that time illustrate a 6.32 year housing land supply at a 5% buffer level, and 5.53 year supply at the 20% buffer, albeit it is noted that this was only draft and requires updating for the 2020-2021 period. The current supply is unknown but the Spatial Options document notes that the need for 360 homes per
year over the course of the Plan (20 years), equating to 7,200 homes total, remains. This figure does not include for assisting other districts in the duty to cooperate or any 5/20% buffer, so could well be higher. Notwithstanding this, there is a clear need to increase the allocation of housing land in the new Local Plan to illustrate the potential for 7,200 homes to be delivered.
2.13 Paragraph 73 highlights the opportunity for larger scale development and the benefits of this approach
in achieving the necessary supply of housing. It is possible that new settlements or extensions to
existing settlements can provide a route to sustainable development.
The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities (including a genuine choice of transport modes).
2.14 Paragraph 23 notes that Local Plans should plan positively for development by allocating sites for
development and identify land where development would be inappropriate due to its environmental or historic significance.
Broad locations for development should be indicated on a key diagram, and landuse designations and allocations identified on a policies map. Strategic policies should provide a clear strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period, in line with the presumption in favour of sustainable development. This should include planning or and allocating sufficient sites to deliver the strategic priorities of the area
2.15 Paragraph 138 of the NPPF refers to the purposes of the Green Belt;
Green Belt serves five purposes:
a) to check the unrestricted sprawl of large built-up areas;
b) to prevent neighbouring towns merging into one another;
c) to assist in safeguarding the countryside from encroachment;
d) to preserve the setting and special character of historic towns; and
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
2.16 Local Plans will be examined by an independent inspector before they are adopted. To be considered
ready for adoption they will need to be shown to be ‘sound’, as per paragraph 35 of the NPPF;
Local plans and spatial development strategies are examined to assess whether they have been
prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are
‘sound’ if they are:
a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
c) Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant. Rochford District Core Strategy and the Allocations Plan
2.17 The key strategic documents in the local development plan are the adopted Core Strategy 2011 and the Allocations Plan 2014. These are both dated documents and would be considered out of date where
the content conflicts with NPPF policy. Nonetheless, they provide a useful basis against which to subsequently consider the options in the New Local Plan consultation.
2.18 The following exerts are of interest;
District
2.41 “Failure to provide affordable housing that meets the needs of the District’s residents may lead to
continued out-migration, to the detriment of the vitality of local communities.” (p31)
Rayleigh
“The largest settlement is Rayleigh which, in 2001, was home to 30,196 people (38% of the District’s
residents at that time).” (p28)
Housing Development
2.39 “As well as directing housing growth to areas of need/demand, and away from unsustainable
locations subject to constraints, the Council must consider the relationship of housing growth to areas
of employment growth.” (p30)
Vision – Medium/Long Term “A range of high-quality, sustainable new dwellings that meet the needs
of local people of all social groups are in place and integrated into communities. The vast majority of
the District’s Green Belt remains undeveloped. New infrastructure has accompanied new residential
development, meeting the need of local communities.” (p41)
Policy H1 – the efficient use of land for housing
“The remaining housing requirement that cannot be delivered through the redevelopment of appropriate previously developed land will be met through extensions to the residential envelopes of existing settlements as outlined in Policy H2.” (p45)
The Green Belt
Housing Objective “Prioritise the redevelopment of appropriate brownfield sites for housing, to minimise the release of Green Belt land for development” (p41).
“In order to fulfil the requirements of the East of England Plan and to meet the housing need of the District, the Council is required to allocate additional land for residential development, including land, which is currently allocated as Green Belt, due to the limited supply” (p45).
“it must be also mindful of the need to maintain Green Belt as far as possible.” (p46)
2.19 The extant Core Strategy outlines a strong protection of the Green Belt, as per national policy. However, this was predicated on an old housing need and supply, which is now out of line with current demand
and what can be achieved through existing permissions, allocations, brownfield sites and windfall forecasts. Rayleigh is considered a focal settlement and one that has both a sizeable population already and the infrastructure to service those residents.
2.20 Notwithstanding the above, the Council recognised the need to review the designation of the Green Belt in the face of the relatively low housing need at the time the Core Strategy was drafted. It states;
The Council will continue to support the principles of restricting development in the Green Belt, as set out in PPG2, and will preserve the character and openness of the Green Belt. However, a small proportion of the District’s Green Belt will have to have its designation reviewed to allow the development of additional housing and business premises, taking account of the very limited
opportunities to accommodate further development within existing settlements.
2.21 This position regarding housing need and lack of land supply (before moving onto Green Belt land), will
be felt more acutely during the drafting of this new Local Plan.

3. NEW LOCAL PLAN: SPATIAL OPTIONS QUESTIONS
3.1 It is noted that in its introductory section the Spatial Options document considers the need to “coordinate the delivery of much needed housing”. It also states that;

“Rochford should consider every opportunity to meet its own housing needs within its own authority
area, with a focus on genuinely affordable housing that meets genuinely local needs”
3.2 Given the extent of Green Belt in this part of South East Essex, it is considered likely that as in Rochford,
surrounding districts will find it difficult to deliver their full quota of required housing land supply within
existing settlements and on brownfield land, i.e. there will be a need to use Green Belt. To this end it is
submitted that they will be unable to offer assistance to Rochford in providing surplus land to accommodate housing delivery. We support the Spatial Options document in the above assertion.
3.3 This will necessitate a review of Green Belt designation to a greater extent than that previously carried out with the adopted Core Strategy. As noted above, Green Belt serves 5 purposes; “to check the
unrestricted sprawl of large built-up areas, to prevent neighbouring towns merging into one another, to
assist in safeguarding the countryside from encroachment, to preserve the setting and special character of historic towns and to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.” It is submitted that where these matters are less acutely felt, and in those areas of lesser
landscape quality, new housing land allocations could be proposed within the currently designated Green Belt, to assist with achieving the necessary housing land supply. The Core Strategy acknowledges this approach;
The term ‘Green Belt’ refers to a planning designation and is not necessarily a description of quality of
the land. Land designated as Green Belt can include, primarily for historical reasons, developed land and
brownfield sites. As such, whilst it is considered that all land currently designated as Green Belt helps achieve the five green belt purposes as set out in the NPPF to at least a degree, some green belt land is less worthy of continued protection.
3.4 This is acknowledged in the New Local Plan: Spatial Options document, which considers 4no. spatial
options for delivery of necessary development and infrastructure. All but Option 1 would necessitate
the use of Green Belt.
Question 5. Do you agree with the settlement hierarchy presented? If not, what changes do you think
are required?
3.6 We support the settlement hierarchy presented. This focuses development at the most appropriate
settlements in the order of their ability to support new development. Rayleigh benefits from a strong existing resident mass and thus has a viability for growth and expansion of businesses and communities. We would submit that the majority of new development, and residential site allocations, should be around Rayleigh.
Question 6. Which of the identified strategy options do you consider should be taken forward in the Plan?
3.7 We support Strategy Option 2 and in particular Option 2a. This option provides a balanced response to the housing need of 7,200 – 10,800 dwellings (delivering between 8,700 to 10,700 dwellings), the necessary mass to support a good level of new infrastructure and facilities, and the need to minimise as much as possible the release of Green Belt for development.
3.8 Option 1 would not deliver the required housing land necessary to respond to the identified housing
need over the course of the Plan, and as discussed, it is considered unlikely that other surrounding districts would be able to assist with additional land. Option 3 would necessitate a significant release of Green Belt and would have a significant impact on the character of the surrounding Green Belt due to the size of a new villages/towns. As with to Option 3, Option 4 would require a sizeable release of Green Belt and significant impact on surrounding land around any new villages/towns.
3.9 Figure 23 of the Spatial Options document provides a Sustainability Appraisal of the various Options and this illustrates the balance that Option 2 provides, albeit it is noted that Option 4 scores best.
However, due to its mix of strategies for the delivery of development we would note a concern that it would pose significant complexities in implementing. In order to achieve the development required the full mix of strategies would be required, and if one were to fail or be delayed (as is a real risk with new villages/towns), a shortfall in housing or employment space could result, putting the Council’s position at risk.
Question 56a. Do you agree with our vision for Rayleigh? Is there anything you feel is missing?
3.10 We support the vision for Rayleigh. It is and should remain the only Tier 1 settlement given its existing
population mass, infrastructure/facilities provision and ability to accommodate significant growth relative to other settlements. The growth and expansion of Rayleigh with urban extensions would generate a sizeable portion of the housing quota required to respond to the identified housing need. Through the development of the majority of those sites submitted for consideration around the edges of Rayleigh, this focal settlement could alleviate pressures on more rural settings and larger swathes of
Green Belt throughout the rest of the district.
Questions 56b, 56c, 56d and 56e.
3.11 It is submitted that land at Call for Sites references CFS044 and CFS256 would offer an opportunity to
contribute to identified housing need delivery in a Green Belt location that could maintain the five purposes of Green Belt and in a location that has reduced landscape quality but is also well screened from surrounding areas. The attached initial Scoping Landscape Statement and Transport Planning Technical Note support that proposal.
3.12 The Council have carried out an initial assessment of these sites, as below.

[SEE DOCUMENT FOR IMAGE]

3.13 Whilst the appraisals above highlight the impact upon Green Belt, as discussed it is submitted that most
virgin sites put forward will impact upon that designation. It is considered that a sequential assessment
of the districts Green Belt would be appropriate in this regard and could highlight those sites that would
have a lesser visual impact and still maintain the purposes of Green Belt as best possible. The above
sites are expected to respond positively in both regards. The accompanying Scoping Landscape Statement concludes thus;
The landscape is subdivided into paddocks and is not of the highest visual quality, but the structure is strong and there are valued elements within it. The site is well contained by woodland and hedgerows, which should be used to inform design work for any forthcoming development proposal. Development of the site would take place within the current Green Belt designation / boundary, but the impact of development upon the openness of the Green Belt would be limited, due to the site's location adjacent to the existing urban area, its location within an enclave of landscape defined by the urban area and the A127, and the fact that the site's character is already enclosed, offering few publicly
accessible viewpoints.
Development of the site would not bring about coalescence of settlement, due to the strong landscape
barrier represented by the A127 itself, and the extensive Pound Wood Nature Reserve to the south of it,
separating the site from Daws Heath. Should the site be brought forward for development, design work should be informed by a full understanding of local landscape and visual character. The enclosed and compartmentalised character of the site should be retained and used as a constraint for design.
3.14 The Sustainability Appraisal also scores the sites low on ‘Existing site access’. However, the
accompanying Transport Planning Technical Note identifies 3no. possible accesses to the site, two of
which would be new accesses. It comments thus;
A number of options have been identified as having good potential for providing vehicle access to the site to unlock its development potential and deliver between 200 and 300 residential dwellings as part of the new Rochford Local Plan.
Providing a sustainable transport link from the site to the north is considered important to unlock the full sustainable development potential of the site as there are a number of local facilities and services on this section of A1015 Eastwood Road including bus stops.
3.15 It is submitted that in other key criteria the sites score well in the Sustainability Appraisal and in
combination would provide a high scoring option as a residential/housing allocation (including market
and affordable).
3.16 It is submitted that generally the area of these sites is well suited to accommodating a moderate
amount of new development. It is well enclosed by existing built form with the edge of Rayleigh to the
immediate north and the A127 to the immediate south. As such it would not lead to an interruption of
open land and countryside to the detriment of the landscape and quality of Green Belt. Furthermore,
this area scores well in terms of its Walking Completeness Score, in particular the two sites identified,
which are adjacent to land scoring of 8-10.
3.17 In combination with other similarly sized sites in this location to the south east of Rayleigh, a good level
of housing land supply could be achieved across numerous parcels (each able to provide in the region
100 to 400 dwellings). This would not necessitate significant new infrastructure but rather upgrades to
existing. Furthermore, the delivery of this volume of dwellings across several parcels would allow for
the retention of important green spaces and structural planting in between, which could serve to
maintain the green character of this urban/rural fringe and complement the Green Belt beyond.
3.18 We Support the allocation of Open Space and Local Wildlife Sites to the east of Rayleigh. It is
submitted that development on or adjacent to these protected sites could negatively impact upon
them, through increased light/air/noise pollution and walker/visitors (in the case of the wildlife sites).
There is an added logic in retaining these sites as open space and wildlife sites (for their intrinsic value)
as they could double as Green Belt.

1. INTRODUCTION
1.1 Rochford District Council is seeking feedback from interested parties on its identified ‘Options’ in the
New Local Plan: Spatial Options document.
1.2 Lee Evans Planning have been instructed to make representations on behalf of Ms Suzanne Redwood,
Mr Roger Lambourne and Mr Colin Humphries.
1.3 Section 2 sets out relevant extant Planning Policy considerations.
1.4 Section 3 reviews and comments on the Spatial Options document, including providing responses to
Questions outlined in the Consultation.

2. CURRENT POLICY POSITION
National Planning Policy Framework
2.1 The National Planning Policy Framework sets out the meaning and role of sustainable development and how planning can help to achieve it. At a very high level, the objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs.
2.2 A rising population and longer life expectancy requires growth and an increase in the volume and
choice of housing. The NPPF identifies the need to complement this growth with high standards of
design and to protect our built, natural and historic environments. The NPPF also highlights the
fundamental role that sustainable development plays in the plan-making and decision making process.
So that sustainable development is pursued in a positive way, at the heart of the Framework is a presumption in favour of sustainable development
2.3 The NPPF serves to provide a framework around which the community and the councils can produce
the local and neighbourhood plans, which reflect the needs and priorities of the community.
The National Planning Policy Framework must be taken into account in preparing the development plan, and is a material consideration in planning decisions.
2.5 Paragraph 8 of the NPPF reiterates the role of the planning system and the contribution it must make to realising sustainable development. Sustainable development has three dimensions to it; economic,
social and environmental.
• an economic objective – to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and
coordinating the provision of infrastructure;
• a social objective – to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering well-designed, beautiful and safe places, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being; and
• an environmental objective – to protect and enhance our natural, built and historic environment; including making effective use of land, improving biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate
change, including moving to a low carbon economy.
2.6 The NPPF considers in further detail the need to protect and improve the quality of the built, natural and historic environment. One aspect of this aim is to widen the choice of quality homes. This can be achieved through the plan-making process, as discussed in paragraph 11.
Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that:
a) all plans should promote a sustainable pattern of development that seeks to: meet the development
needs of their area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects;
b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:
i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or
ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when
assessed against the policies in this Framework taken as a whole.
2.7 Paragraph 60 notes the need to boost the supply of homes through land allocation. To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay.
2.8 Paragraph 61 outlines the approach to determining housing need. The New Local Plan; Spatial Options
document is unclear on the degree to which the duty to cooperate has been explored with neighbouring areas, suggesting that at present the assumption should be made that all identified housing need must be delivered within the district.
To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.
2.9 Each year the local planning authority will identify their supply of specific deliverable sites to provide the next five years of housing with an additional 5% buffer. This will allow for both choice and competition in the market. Developable sites that can accommodate for years 6-10 of the plan period and beyond will also be identified.
2.10 A 10% buffer should be provided “where the local planning authority wishes to demonstrate a five year
supply of deliverable sites through an annual position statement or recently adopted plan, to account for any fluctuations in the market during that year”.
2.11 A 20% buffer should be provided “where there has been significant under delivery of housing over the
previous three years, to improve the prospect of achieving the planned supply”. The NPPG elaborates
by stating that “A 20% buffer will apply to a local planning authority’s five-year land supply if housing delivery falls below 85%”.
2.12 If a five year supply of deliverable housing cannot be demonstrated policies relating to the supply of housing should not be considered to be up-to-date. All housing applications should be considered on the basis of a presumption in favour of sustainable development as has been discussed above. The most recent Authority Monitoring Report (draft 2019-2020), suggests that there exists a district housing need of 1,800 homes over a five year period (equating to 360 homes per year) and that the Council could at that time illustrate a 6.32 year housing land supply at a 5% buffer level, and 5.53 year supply at the 20% buffer, albeit it is noted that this was only draft and requires updating for the 2020-2021 period. The current supply is unknown but the Spatial Options document notes that the need for 360 homes per
year over the course of the Plan (20 years), equating to 7,200 homes total, remains. This figure does not include for assisting other districts in the duty to cooperate or any 5/20% buffer, so could well be higher. Notwithstanding this, there is a clear need to increase the allocation of housing land in the new Local Plan to illustrate the potential for 7,200 homes to be delivered.
2.13 Paragraph 73 highlights the opportunity for larger scale development and the benefits of this approach
in achieving the necessary supply of housing. It is possible that new settlements or extensions to
existing settlements can provide a route to sustainable development.
The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities (including a genuine choice of transport modes).
2.14 Paragraph 23 notes that Local Plans should plan positively for development by allocating sites for
development and identify land where development would be inappropriate due to its environmental or historic significance.
Broad locations for development should be indicated on a key diagram, and landuse designations and allocations identified on a policies map. Strategic policies should provide a clear strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period, in line with the presumption in favour of sustainable development. This should include planning or and allocating sufficient sites to deliver the strategic priorities of the area
2.15 Paragraph 138 of the NPPF refers to the purposes of the Green Belt;
Green Belt serves five purposes:
a) to check the unrestricted sprawl of large built-up areas;
b) to prevent neighbouring towns merging into one another;
c) to assist in safeguarding the countryside from encroachment;
d) to preserve the setting and special character of historic towns; and
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
2.16 Local Plans will be examined by an independent inspector before they are adopted. To be considered
ready for adoption they will need to be shown to be ‘sound’, as per paragraph 35 of the NPPF;
Local plans and spatial development strategies are examined to assess whether they have been
prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are
‘sound’ if they are:
a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
c) Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant. Rochford District Core Strategy and the Allocations Plan
2.17 The key strategic documents in the local development plan are the adopted Core Strategy 2011 and the Allocations Plan 2014. These are both dated documents and would be considered out of date where
the content conflicts with NPPF policy. Nonetheless, they provide a useful basis against which to subsequently consider the options in the New Local Plan consultation.
2.18 The following exerts are of interest;
District
2.41 “Failure to provide affordable housing that meets the needs of the District’s residents may lead to
continued out-migration, to the detriment of the vitality of local communities.” (p31)
Rayleigh
“The largest settlement is Rayleigh which, in 2001, was home to 30,196 people (38% of the District’s
residents at that time).” (p28)
Housing Development
2.39 “As well as directing housing growth to areas of need/demand, and away from unsustainable
locations subject to constraints, the Council must consider the relationship of housing growth to areas
of employment growth.” (p30)
Vision – Medium/Long Term “A range of high-quality, sustainable new dwellings that meet the needs
of local people of all social groups are in place and integrated into communities. The vast majority of
the District’s Green Belt remains undeveloped. New infrastructure has accompanied new residential
development, meeting the need of local communities.” (p41)
Policy H1 – the efficient use of land for housing
“The remaining housing requirement that cannot be delivered through the redevelopment of appropriate previously developed land will be met through extensions to the residential envelopes of existing settlements as outlined in Policy H2.” (p45)
The Green Belt
Housing Objective “Prioritise the redevelopment of appropriate brownfield sites for housing, to minimise the release of Green Belt land for development” (p41).
“In order to fulfil the requirements of the East of England Plan and to meet the housing need of the District, the Council is required to allocate additional land for residential development, including land, which is currently allocated as Green Belt, due to the limited supply” (p45).
“it must be also mindful of the need to maintain Green Belt as far as possible.” (p46)
2.19 The extant Core Strategy outlines a strong protection of the Green Belt, as per national policy. However, this was predicated on an old housing need and supply, which is now out of line with current demand
and what can be achieved through existing permissions, allocations, brownfield sites and windfall forecasts. Rayleigh is considered a focal settlement and one that has both a sizeable population already and the infrastructure to service those residents.
2.20 Notwithstanding the above, the Council recognised the need to review the designation of the Green Belt in the face of the relatively low housing need at the time the Core Strategy was drafted. It states;
The Council will continue to support the principles of restricting development in the Green Belt, as set out in PPG2, and will preserve the character and openness of the Green Belt. However, a small proportion of the District’s Green Belt will have to have its designation reviewed to allow the development of additional housing and business premises, taking account of the very limited
opportunities to accommodate further development within existing settlements.
2.21 This position regarding housing need and lack of land supply (before moving onto Green Belt land), will
be felt more acutely during the drafting of this new Local Plan.

3. NEW LOCAL PLAN: SPATIAL OPTIONS QUESTIONS
3.1 It is noted that in its introductory section the Spatial Options document considers the need to “coordinate the delivery of much needed housing”. It also states that;

“Rochford should consider every opportunity to meet its own housing needs within its own authority
area, with a focus on genuinely affordable housing that meets genuinely local needs”
3.2 Given the extent of Green Belt in this part of South East Essex, it is considered likely that as in Rochford,
surrounding districts will find it difficult to deliver their full quota of required housing land supply within
existing settlements and on brownfield land, i.e. there will be a need to use Green Belt. To this end it is
submitted that they will be unable to offer assistance to Rochford in providing surplus land to accommodate housing delivery. We support the Spatial Options document in the above assertion.
3.3 This will necessitate a review of Green Belt designation to a greater extent than that previously carried out with the adopted Core Strategy. As noted above, Green Belt serves 5 purposes; “to check the
unrestricted sprawl of large built-up areas, to prevent neighbouring towns merging into one another, to
assist in safeguarding the countryside from encroachment, to preserve the setting and special character of historic towns and to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.” It is submitted that where these matters are less acutely felt, and in those areas of lesser
landscape quality, new housing land allocations could be proposed within the currently designated Green Belt, to assist with achieving the necessary housing land supply. The Core Strategy acknowledges this approach;
The term ‘Green Belt’ refers to a planning designation and is not necessarily a description of quality of
the land. Land designated as Green Belt can include, primarily for historical reasons, developed land and
brownfield sites. As such, whilst it is considered that all land currently designated as Green Belt helps achieve the five green belt purposes as set out in the NPPF to at least a degree, some green belt land is less worthy of continued protection.
3.4 This is acknowledged in the New Local Plan: Spatial Options document, which considers 4no. spatial
options for delivery of necessary development and infrastructure. All but Option 1 would necessitate
the use of Green Belt.
Question 5. Do you agree with the settlement hierarchy presented? If not, what changes do you think
are required?
3.6 We support the settlement hierarchy presented. This focuses development at the most appropriate
settlements in the order of their ability to support new development. Rayleigh benefits from a strong existing resident mass and thus has a viability for growth and expansion of businesses and communities. We would submit that the majority of new development, and residential site allocations, should be around Rayleigh.
Question 6. Which of the identified strategy options do you consider should be taken forward in the Plan?
3.7 We support Strategy Option 2 and in particular Option 2a. This option provides a balanced response to the housing need of 7,200 – 10,800 dwellings (delivering between 8,700 to 10,700 dwellings), the necessary mass to support a good level of new infrastructure and facilities, and the need to minimise as much as possible the release of Green Belt for development.
3.8 Option 1 would not deliver the required housing land necessary to respond to the identified housing
need over the course of the Plan, and as discussed, it is considered unlikely that other surrounding districts would be able to assist with additional land. Option 3 would necessitate a significant release of Green Belt and would have a significant impact on the character of the surrounding Green Belt due to the size of a new villages/towns. As with to Option 3, Option 4 would require a sizeable release of Green Belt and significant impact on surrounding land around any new villages/towns.
3.9 Figure 23 of the Spatial Options document provides a Sustainability Appraisal of the various Options and this illustrates the balance that Option 2 provides, albeit it is noted that Option 4 scores best.
However, due to its mix of strategies for the delivery of development we would note a concern that it would pose significant complexities in implementing. In order to achieve the development required the full mix of strategies would be required, and if one were to fail or be delayed (as is a real risk with new villages/towns), a shortfall in housing or employment space could result, putting the Council’s position at risk.
Question 56a. Do you agree with our vision for Rayleigh? Is there anything you feel is missing?
3.10 We support the vision for Rayleigh. It is and should remain the only Tier 1 settlement given its existing
population mass, infrastructure/facilities provision and ability to accommodate significant growth relative to other settlements. The growth and expansion of Rayleigh with urban extensions would generate a sizeable portion of the housing quota required to respond to the identified housing need. Through the development of the majority of those sites submitted for consideration around the edges of Rayleigh, this focal settlement could alleviate pressures on more rural settings and larger swathes of
Green Belt throughout the rest of the district.
Questions 56b, 56c, 56d and 56e.
3.11 It is submitted that land at Call for Sites references CFS044 and CFS256 would offer an opportunity to
contribute to identified housing need delivery in a Green Belt location that could maintain the five purposes of Green Belt and in a location that has reduced landscape quality but is also well screened from surrounding areas. The attached initial Scoping Landscape Statement and Transport Planning Technical Note support that proposal.
3.12 The Council have carried out an initial assessment of these sites, as below.

[SEE DOCUMENT FOR IMAGE]

3.13 Whilst the appraisals above highlight the impact upon Green Belt, as discussed it is submitted that most
virgin sites put forward will impact upon that designation. It is considered that a sequential assessment
of the districts Green Belt would be appropriate in this regard and could highlight those sites that would
have a lesser visual impact and still maintain the purposes of Green Belt as best possible. The above
sites are expected to respond positively in both regards. The accompanying Scoping Landscape Statement concludes thus;
The landscape is subdivided into paddocks and is not of the highest visual quality, but the structure is strong and there are valued elements within it. The site is well contained by woodland and hedgerows, which should be used to inform design work for any forthcoming development proposal. Development of the site would take place within the current Green Belt designation / boundary, but the impact of development upon the openness of the Green Belt would be limited, due to the site's location adjacent to the existing urban area, its location within an enclave of landscape defined by the urban area and the A127, and the fact that the site's character is already enclosed, offering few publicly
accessible viewpoints.
Development of the site would not bring about coalescence of settlement, due to the strong landscape
barrier represented by the A127 itself, and the extensive Pound Wood Nature Reserve to the south of it,
separating the site from Daws Heath. Should the site be brought forward for development, design work should be informed by a full understanding of local landscape and visual character. The enclosed and compartmentalised character of the site should be retained and used as a constraint for design.
3.14 The Sustainability Appraisal also scores the sites low on ‘Existing site access’. However, the
accompanying Transport Planning Technical Note identifies 3no. possible accesses to the site, two of
which would be new accesses. It comments thus;
A number of options have been identified as having good potential for providing vehicle access to the site to unlock its development potential and deliver between 200 and 300 residential dwellings as part of the new Rochford Local Plan.
Providing a sustainable transport link from the site to the north is considered important to unlock the full sustainable development potential of the site as there are a number of local facilities and services on this section of A1015 Eastwood Road including bus stops.
3.15 It is submitted that in other key criteria the sites score well in the Sustainability Appraisal and in
combination would provide a high scoring option as a residential/housing allocation (including market
and affordable).
3.16 It is submitted that generally the area of these sites is well suited to accommodating a moderate
amount of new development. It is well enclosed by existing built form with the edge of Rayleigh to the
immediate north and the A127 to the immediate south. As such it would not lead to an interruption of
open land and countryside to the detriment of the landscape and quality of Green Belt. Furthermore,
this area scores well in terms of its Walking Completeness Score, in particular the two sites identified,
which are adjacent to land scoring of 8-10.
3.17 In combination with other similarly sized sites in this location to the south east of Rayleigh, a good level
of housing land supply could be achieved across numerous parcels (each able to provide in the region
100 to 400 dwellings). This would not necessitate significant new infrastructure but rather upgrades to
existing. Furthermore, the delivery of this volume of dwellings across several parcels would allow for
the retention of important green spaces and structural planting in between, which could serve to
maintain the green character of this urban/rural fringe and complement the Green Belt beyond.
3.18 We Support the allocation of Open Space and Local Wildlife Sites to the east of Rayleigh. It is
submitted that development on or adjacent to these protected sites could negatively impact upon
them, through increased light/air/noise pollution and walker/visitors (in the case of the wildlife sites).
There is an added logic in retaining these sites as open space and wildlife sites (for their intrinsic value)
as they could double as Green Belt.

1. INTRODUCTION
1.1 Rochford District Council is seeking feedback from interested parties on its identified ‘Options’ in the
New Local Plan: Spatial Options document.
1.2 Lee Evans Planning have been instructed to make representations on behalf of Ms Suzanne Redwood,
Mr Roger Lambourne and Mr Colin Humphries.
1.3 Section 2 sets out relevant extant Planning Policy considerations.
1.4 Section 3 reviews and comments on the Spatial Options document, including providing responses to
Questions outlined in the Consultation.

2. CURRENT POLICY POSITION
National Planning Policy Framework
2.1 The National Planning Policy Framework sets out the meaning and role of sustainable development and how planning can help to achieve it. At a very high level, the objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs.
2.2 A rising population and longer life expectancy requires growth and an increase in the volume and
choice of housing. The NPPF identifies the need to complement this growth with high standards of
design and to protect our built, natural and historic environments. The NPPF also highlights the
fundamental role that sustainable development plays in the plan-making and decision making process.
So that sustainable development is pursued in a positive way, at the heart of the Framework is a presumption in favour of sustainable development
2.3 The NPPF serves to provide a framework around which the community and the councils can produce
the local and neighbourhood plans, which reflect the needs and priorities of the community.
The National Planning Policy Framework must be taken into account in preparing the development plan, and is a material consideration in planning decisions.
2.5 Paragraph 8 of the NPPF reiterates the role of the planning system and the contribution it must make to realising sustainable development. Sustainable development has three dimensions to it; economic,
social and environmental.
• an economic objective – to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and
coordinating the provision of infrastructure;
• a social objective – to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering well-designed, beautiful and safe places, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being; and
• an environmental objective – to protect and enhance our natural, built and historic environment; including making effective use of land, improving biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate
change, including moving to a low carbon economy.
2.6 The NPPF considers in further detail the need to protect and improve the quality of the built, natural and historic environment. One aspect of this aim is to widen the choice of quality homes. This can be achieved through the plan-making process, as discussed in paragraph 11.
Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that:
a) all plans should promote a sustainable pattern of development that seeks to: meet the development
needs of their area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects;
b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:
i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or
ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when
assessed against the policies in this Framework taken as a whole.
2.7 Paragraph 60 notes the need to boost the supply of homes through land allocation. To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay.
2.8 Paragraph 61 outlines the approach to determining housing need. The New Local Plan; Spatial Options
document is unclear on the degree to which the duty to cooperate has been explored with neighbouring areas, suggesting that at present the assumption should be made that all identified housing need must be delivered within the district.
To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.
2.9 Each year the local planning authority will identify their supply of specific deliverable sites to provide the next five years of housing with an additional 5% buffer. This will allow for both choice and competition in the market. Developable sites that can accommodate for years 6-10 of the plan period and beyond will also be identified.
2.10 A 10% buffer should be provided “where the local planning authority wishes to demonstrate a five year
supply of deliverable sites through an annual position statement or recently adopted plan, to account for any fluctuations in the market during that year”.
2.11 A 20% buffer should be provided “where there has been significant under delivery of housing over the
previous three years, to improve the prospect of achieving the planned supply”. The NPPG elaborates
by stating that “A 20% buffer will apply to a local planning authority’s five-year land supply if housing delivery falls below 85%”.
2.12 If a five year supply of deliverable housing cannot be demonstrated policies relating to the supply of housing should not be considered to be up-to-date. All housing applications should be considered on the basis of a presumption in favour of sustainable development as has been discussed above. The most recent Authority Monitoring Report (draft 2019-2020), suggests that there exists a district housing need of 1,800 homes over a five year period (equating to 360 homes per year) and that the Council could at that time illustrate a 6.32 year housing land supply at a 5% buffer level, and 5.53 year supply at the 20% buffer, albeit it is noted that this was only draft and requires updating for the 2020-2021 period. The current supply is unknown but the Spatial Options document notes that the need for 360 homes per
year over the course of the Plan (20 years), equating to 7,200 homes total, remains. This figure does not include for assisting other districts in the duty to cooperate or any 5/20% buffer, so could well be higher. Notwithstanding this, there is a clear need to increase the allocation of housing land in the new Local Plan to illustrate the potential for 7,200 homes to be delivered.
2.13 Paragraph 73 highlights the opportunity for larger scale development and the benefits of this approach
in achieving the necessary supply of housing. It is possible that new settlements or extensions to
existing settlements can provide a route to sustainable development.
The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities (including a genuine choice of transport modes).
2.14 Paragraph 23 notes that Local Plans should plan positively for development by allocating sites for
development and identify land where development would be inappropriate due to its environmental or historic significance.
Broad locations for development should be indicated on a key diagram, and landuse designations and allocations identified on a policies map. Strategic policies should provide a clear strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period, in line with the presumption in favour of sustainable development. This should include planning or and allocating sufficient sites to deliver the strategic priorities of the area
2.15 Paragraph 138 of the NPPF refers to the purposes of the Green Belt;
Green Belt serves five purposes:
a) to check the unrestricted sprawl of large built-up areas;
b) to prevent neighbouring towns merging into one another;
c) to assist in safeguarding the countryside from encroachment;
d) to preserve the setting and special character of historic towns; and
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
2.16 Local Plans will be examined by an independent inspector before they are adopted. To be considered
ready for adoption they will need to be shown to be ‘sound’, as per paragraph 35 of the NPPF;
Local plans and spatial development strategies are examined to assess whether they have been
prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are
‘sound’ if they are:
a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
c) Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant. Rochford District Core Strategy and the Allocations Plan
2.17 The key strategic documents in the local development plan are the adopted Core Strategy 2011 and the Allocations Plan 2014. These are both dated documents and would be considered out of date where
the content conflicts with NPPF policy. Nonetheless, they provide a useful basis against which to subsequently consider the options in the New Local Plan consultation.
2.18 The following exerts are of interest;
District
2.41 “Failure to provide affordable housing that meets the needs of the District’s residents may lead to
continued out-migration, to the detriment of the vitality of local communities.” (p31)
Rayleigh
“The largest settlement is Rayleigh which, in 2001, was home to 30,196 people (38% of the District’s
residents at that time).” (p28)
Housing Development
2.39 “As well as directing housing growth to areas of need/demand, and away from unsustainable
locations subject to constraints, the Council must consider the relationship of housing growth to areas
of employment growth.” (p30)
Vision – Medium/Long Term “A range of high-quality, sustainable new dwellings that meet the needs
of local people of all social groups are in place and integrated into communities. The vast majority of
the District’s Green Belt remains undeveloped. New infrastructure has accompanied new residential
development, meeting the need of local communities.” (p41)
Policy H1 – the efficient use of land for housing
“The remaining housing requirement that cannot be delivered through the redevelopment of appropriate previously developed land will be met through extensions to the residential envelopes of existing settlements as outlined in Policy H2.” (p45)
The Green Belt
Housing Objective “Prioritise the redevelopment of appropriate brownfield sites for housing, to minimise the release of Green Belt land for development” (p41).
“In order to fulfil the requirements of the East of England Plan and to meet the housing need of the District, the Council is required to allocate additional land for residential development, including land, which is currently allocated as Green Belt, due to the limited supply” (p45).
“it must be also mindful of the need to maintain Green Belt as far as possible.” (p46)
2.19 The extant Core Strategy outlines a strong protection of the Green Belt, as per national policy. However, this was predicated on an old housing need and supply, which is now out of line with current demand
and what can be achieved through existing permissions, allocations, brownfield sites and windfall forecasts. Rayleigh is considered a focal settlement and one that has both a sizeable population already and the infrastructure to service those residents.
2.20 Notwithstanding the above, the Council recognised the need to review the designation of the Green Belt in the face of the relatively low housing need at the time the Core Strategy was drafted. It states;
The Council will continue to support the principles of restricting development in the Green Belt, as set out in PPG2, and will preserve the character and openness of the Green Belt. However, a small proportion of the District’s Green Belt will have to have its designation reviewed to allow the development of additional housing and business premises, taking account of the very limited
opportunities to accommodate further development within existing settlements.
2.21 This position regarding housing need and lack of land supply (before moving onto Green Belt land), will
be felt more acutely during the drafting of this new Local Plan.

3. NEW LOCAL PLAN: SPATIAL OPTIONS QUESTIONS
3.1 It is noted that in its introductory section the Spatial Options document considers the need to “coordinate the delivery of much needed housing”. It also states that;

“Rochford should consider every opportunity to meet its own housing needs within its own authority
area, with a focus on genuinely affordable housing that meets genuinely local needs”
3.2 Given the extent of Green Belt in this part of South East Essex, it is considered likely that as in Rochford,
surrounding districts will find it difficult to deliver their full quota of required housing land supply within
existing settlements and on brownfield land, i.e. there will be a need to use Green Belt. To this end it is
submitted that they will be unable to offer assistance to Rochford in providing surplus land to accommodate housing delivery. We support the Spatial Options document in the above assertion.
3.3 This will necessitate a review of Green Belt designation to a greater extent than that previously carried out with the adopted Core Strategy. As noted above, Green Belt serves 5 purposes; “to check the
unrestricted sprawl of large built-up areas, to prevent neighbouring towns merging into one another, to
assist in safeguarding the countryside from encroachment, to preserve the setting and special character of historic towns and to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.” It is submitted that where these matters are less acutely felt, and in those areas of lesser
landscape quality, new housing land allocations could be proposed within the currently designated Green Belt, to assist with achieving the necessary housing land supply. The Core Strategy acknowledges this approach;
The term ‘Green Belt’ refers to a planning designation and is not necessarily a description of quality of
the land. Land designated as Green Belt can include, primarily for historical reasons, developed land and
brownfield sites. As such, whilst it is considered that all land currently designated as Green Belt helps achieve the five green belt purposes as set out in the NPPF to at least a degree, some green belt land is less worthy of continued protection.
3.4 This is acknowledged in the New Local Plan: Spatial Options document, which considers 4no. spatial
options for delivery of necessary development and infrastructure. All but Option 1 would necessitate
the use of Green Belt.
Question 5. Do you agree with the settlement hierarchy presented? If not, what changes do you think
are required?
3.6 We support the settlement hierarchy presented. This focuses development at the most appropriate
settlements in the order of their ability to support new development. Rayleigh benefits from a strong existing resident mass and thus has a viability for growth and expansion of businesses and communities. We would submit that the majority of new development, and residential site allocations, should be around Rayleigh.
Question 6. Which of the identified strategy options do you consider should be taken forward in the Plan?
3.7 We support Strategy Option 2 and in particular Option 2a. This option provides a balanced response to the housing need of 7,200 – 10,800 dwellings (delivering between 8,700 to 10,700 dwellings), the necessary mass to support a good level of new infrastructure and facilities, and the need to minimise as much as possible the release of Green Belt for development.
3.8 Option 1 would not deliver the required housing land necessary to respond to the identified housing
need over the course of the Plan, and as discussed, it is considered unlikely that other surrounding districts would be able to assist with additional land. Option 3 would necessitate a significant release of Green Belt and would have a significant impact on the character of the surrounding Green Belt due to the size of a new villages/towns. As with to Option 3, Option 4 would require a sizeable release of Green Belt and significant impact on surrounding land around any new villages/towns.
3.9 Figure 23 of the Spatial Options document provides a Sustainability Appraisal of the various Options and this illustrates the balance that Option 2 provides, albeit it is noted that Option 4 scores best.
However, due to its mix of strategies for the delivery of development we would note a concern that it would pose significant complexities in implementing. In order to achieve the development required the full mix of strategies would be required, and if one were to fail or be delayed (as is a real risk with new villages/towns), a shortfall in housing or employment space could result, putting the Council’s position at risk.
Question 56a. Do you agree with our vision for Rayleigh? Is there anything you feel is missing?
3.10 We support the vision for Rayleigh. It is and should remain the only Tier 1 settlement given its existing
population mass, infrastructure/facilities provision and ability to accommodate significant growth relative to other settlements. The growth and expansion of Rayleigh with urban extensions would generate a sizeable portion of the housing quota required to respond to the identified housing need. Through the development of the majority of those sites submitted for consideration around the edges of Rayleigh, this focal settlement could alleviate pressures on more rural settings and larger swathes of
Green Belt throughout the rest of the district.
Questions 56b, 56c, 56d and 56e.
3.11 It is submitted that land at Call for Sites references CFS044 and CFS256 would offer an opportunity to
contribute to identified housing need delivery in a Green Belt location that could maintain the five purposes of Green Belt and in a location that has reduced landscape quality but is also well screened from surrounding areas. The attached initial Scoping Landscape Statement and Transport Planning Technical Note support that proposal.
3.12 The Council have carried out an initial assessment of these sites, as below.

[SEE DOCUMENT FOR IMAGE]

3.13 Whilst the appraisals above highlight the impact upon Green Belt, as discussed it is submitted that most
virgin sites put forward will impact upon that designation. It is considered that a sequential assessment
of the districts Green Belt would be appropriate in this regard and could highlight those sites that would
have a lesser visual impact and still maintain the purposes of Green Belt as best possible. The above
sites are expected to respond positively in both regards. The accompanying Scoping Landscape Statement concludes thus;
The landscape is subdivided into paddocks and is not of the highest visual quality, but the structure is strong and there are valued elements within it. The site is well contained by woodland and hedgerows, which should be used to inform design work for any forthcoming development proposal. Development of the site would take place within the current Green Belt designation / boundary, but the impact of development upon the openness of the Green Belt would be limited, due to the site's location adjacent to the existing urban area, its location within an enclave of landscape defined by the urban area and the A127, and the fact that the site's character is already enclosed, offering few publicly
accessible viewpoints.
Development of the site would not bring about coalescence of settlement, due to the strong landscape
barrier represented by the A127 itself, and the extensive Pound Wood Nature Reserve to the south of it,
separating the site from Daws Heath. Should the site be brought forward for development, design work should be informed by a full understanding of local landscape and visual character. The enclosed and compartmentalised character of the site should be retained and used as a constraint for design.
3.14 The Sustainability Appraisal also scores the sites low on ‘Existing site access’. However, the
accompanying Transport Planning Technical Note identifies 3no. possible accesses to the site, two of
which would be new accesses. It comments thus;
A number of options have been identified as having good potential for providing vehicle access to the site to unlock its development potential and deliver between 200 and 300 residential dwellings as part of the new Rochford Local Plan.
Providing a sustainable transport link from the site to the north is considered important to unlock the full sustainable development potential of the site as there are a number of local facilities and services on this section of A1015 Eastwood Road including bus stops.
3.15 It is submitted that in other key criteria the sites score well in the Sustainability Appraisal and in
combination would provide a high scoring option as a residential/housing allocation (including market
and affordable).
3.16 It is submitted that generally the area of these sites is well suited to accommodating a moderate
amount of new development. It is well enclosed by existing built form with the edge of Rayleigh to the
immediate north and the A127 to the immediate south. As such it would not lead to an interruption of
open land and countryside to the detriment of the landscape and quality of Green Belt. Furthermore,
this area scores well in terms of its Walking Completeness Score, in particular the two sites identified,
which are adjacent to land scoring of 8-10.
3.17 In combination with other similarly sized sites in this location to the south east of Rayleigh, a good level
of housing land supply could be achieved across numerous parcels (each able to provide in the region
100 to 400 dwellings). This would not necessitate significant new infrastructure but rather upgrades to
existing. Furthermore, the delivery of this volume of dwellings across several parcels would allow for
the retention of important green spaces and structural planting in between, which could serve to
maintain the green character of this urban/rural fringe and complement the Green Belt beyond.
3.18 We Support the allocation of Open Space and Local Wildlife Sites to the east of Rayleigh. It is
submitted that development on or adjacent to these protected sites could negatively impact upon
them, through increased light/air/noise pollution and walker/visitors (in the case of the wildlife sites).
There is an added logic in retaining these sites as open space and wildlife sites (for their intrinsic value)
as they could double as Green Belt.

1. INTRODUCTION
1.1 Rochford District Council is seeking feedback from interested parties on its identified ‘Options’ in the
New Local Plan: Spatial Options document.
1.2 Lee Evans Planning have been instructed to make representations on behalf of Ms Suzanne Redwood,
Mr Roger Lambourne and Mr Colin Humphries.
1.3 Section 2 sets out relevant extant Planning Policy considerations.
1.4 Section 3 reviews and comments on the Spatial Options document, including providing responses to
Questions outlined in the Consultation.

2. CURRENT POLICY POSITION
National Planning Policy Framework
2.1 The National Planning Policy Framework sets out the meaning and role of sustainable development and how planning can help to achieve it. At a very high level, the objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs.
2.2 A rising population and longer life expectancy requires growth and an increase in the volume and
choice of housing. The NPPF identifies the need to complement this growth with high standards of
design and to protect our built, natural and historic environments. The NPPF also highlights the
fundamental role that sustainable development plays in the plan-making and decision making process.
So that sustainable development is pursued in a positive way, at the heart of the Framework is a presumption in favour of sustainable development
2.3 The NPPF serves to provide a framework around which the community and the councils can produce
the local and neighbourhood plans, which reflect the needs and priorities of the community.
The National Planning Policy Framework must be taken into account in preparing the development plan, and is a material consideration in planning decisions.
2.5 Paragraph 8 of the NPPF reiterates the role of the planning system and the contribution it must make to realising sustainable development. Sustainable development has three dimensions to it; economic,
social and environmental.
• an economic objective – to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and
coordinating the provision of infrastructure;
• a social objective – to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering well-designed, beautiful and safe places, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being; and
• an environmental objective – to protect and enhance our natural, built and historic environment; including making effective use of land, improving biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate
change, including moving to a low carbon economy.
2.6 The NPPF considers in further detail the need to protect and improve the quality of the built, natural and historic environment. One aspect of this aim is to widen the choice of quality homes. This can be achieved through the plan-making process, as discussed in paragraph 11.
Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that:
a) all plans should promote a sustainable pattern of development that seeks to: meet the development
needs of their area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects;
b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:
i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or
ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when
assessed against the policies in this Framework taken as a whole.
2.7 Paragraph 60 notes the need to boost the supply of homes through land allocation. To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay.
2.8 Paragraph 61 outlines the approach to determining housing need. The New Local Plan; Spatial Options
document is unclear on the degree to which the duty to cooperate has been explored with neighbouring areas, suggesting that at present the assumption should be made that all identified housing need must be delivered within the district.
To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.
2.9 Each year the local planning authority will identify their supply of specific deliverable sites to provide the next five years of housing with an additional 5% buffer. This will allow for both choice and competition in the market. Developable sites that can accommodate for years 6-10 of the plan period and beyond will also be identified.
2.10 A 10% buffer should be provided “where the local planning authority wishes to demonstrate a five year
supply of deliverable sites through an annual position statement or recently adopted plan, to account for any fluctuations in the market during that year”.
2.11 A 20% buffer should be provided “where there has been significant under delivery of housing over the
previous three years, to improve the prospect of achieving the planned supply”. The NPPG elaborates
by stating that “A 20% buffer will apply to a local planning authority’s five-year land supply if housing delivery falls below 85%”.
2.12 If a five year supply of deliverable housing cannot be demonstrated policies relating to the supply of housing should not be considered to be up-to-date. All housing applications should be considered on the basis of a presumption in favour of sustainable development as has been discussed above. The most recent Authority Monitoring Report (draft 2019-2020), suggests that there exists a district housing need of 1,800 homes over a five year period (equating to 360 homes per year) and that the Council could at that time illustrate a 6.32 year housing land supply at a 5% buffer level, and 5.53 year supply at the 20% buffer, albeit it is noted that this was only draft and requires updating for the 2020-2021 period. The current supply is unknown but the Spatial Options document notes that the need for 360 homes per
year over the course of the Plan (20 years), equating to 7,200 homes total, remains. This figure does not include for assisting other districts in the duty to cooperate or any 5/20% buffer, so could well be higher. Notwithstanding this, there is a clear need to increase the allocation of housing land in the new Local Plan to illustrate the potential for 7,200 homes to be delivered.
2.13 Paragraph 73 highlights the opportunity for larger scale development and the benefits of this approach
in achieving the necessary supply of housing. It is possible that new settlements or extensions to
existing settlements can provide a route to sustainable development.
The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities (including a genuine choice of transport modes).
2.14 Paragraph 23 notes that Local Plans should plan positively for development by allocating sites for
development and identify land where development would be inappropriate due to its environmental or historic significance.
Broad locations for development should be indicated on a key diagram, and landuse designations and allocations identified on a policies map. Strategic policies should provide a clear strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period, in line with the presumption in favour of sustainable development. This should include planning or and allocating sufficient sites to deliver the strategic priorities of the area
2.15 Paragraph 138 of the NPPF refers to the purposes of the Green Belt;
Green Belt serves five purposes:
a) to check the unrestricted sprawl of large built-up areas;
b) to prevent neighbouring towns merging into one another;
c) to assist in safeguarding the countryside from encroachment;
d) to preserve the setting and special character of historic towns; and
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
2.16 Local Plans will be examined by an independent inspector before they are adopted. To be considered
ready for adoption they will need to be shown to be ‘sound’, as per paragraph 35 of the NPPF;
Local plans and spatial development strategies are examined to assess whether they have been
prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are
‘sound’ if they are:
a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
c) Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant. Rochford District Core Strategy and the Allocations Plan
2.17 The key strategic documents in the local development plan are the adopted Core Strategy 2011 and the Allocations Plan 2014. These are both dated documents and would be considered out of date where
the content conflicts with NPPF policy. Nonetheless, they provide a useful basis against which to subsequently consider the options in the New Local Plan consultation.
2.18 The following exerts are of interest;
District
2.41 “Failure to provide affordable housing that meets the needs of the District’s residents may lead to
continued out-migration, to the detriment of the vitality of local communities.” (p31)
Rayleigh
“The largest settlement is Rayleigh which, in 2001, was home to 30,196 people (38% of the District’s
residents at that time).” (p28)
Housing Development
2.39 “As well as directing housing growth to areas of need/demand, and away from unsustainable
locations subject to constraints, the Council must consider the relationship of housing growth to areas
of employment growth.” (p30)
Vision – Medium/Long Term “A range of high-quality, sustainable new dwellings that meet the needs
of local people of all social groups are in place and integrated into communities. The vast majority of
the District’s Green Belt remains undeveloped. New infrastructure has accompanied new residential
development, meeting the need of local communities.” (p41)
Policy H1 – the efficient use of land for housing
“The remaining housing requirement that cannot be delivered through the redevelopment of appropriate previously developed land will be met through extensions to the residential envelopes of existing settlements as outlined in Policy H2.” (p45)
The Green Belt
Housing Objective “Prioritise the redevelopment of appropriate brownfield sites for housing, to minimise the release of Green Belt land for development” (p41).
“In order to fulfil the requirements of the East of England Plan and to meet the housing need of the District, the Council is required to allocate additional land for residential development, including land, which is currently allocated as Green Belt, due to the limited supply” (p45).
“it must be also mindful of the need to maintain Green Belt as far as possible.” (p46)
2.19 The extant Core Strategy outlines a strong protection of the Green Belt, as per national policy. However, this was predicated on an old housing need and supply, which is now out of line with current demand
and what can be achieved through existing permissions, allocations, brownfield sites and windfall forecasts. Rayleigh is considered a focal settlement and one that has both a sizeable population already and the infrastructure to service those residents.
2.20 Notwithstanding the above, the Council recognised the need to review the designation of the Green Belt in the face of the relatively low housing need at the time the Core Strategy was drafted. It states;
The Council will continue to support the principles of restricting development in the Green Belt, as set out in PPG2, and will preserve the character and openness of the Green Belt. However, a small proportion of the District’s Green Belt will have to have its designation reviewed to allow the development of additional housing and business premises, taking account of the very limited
opportunities to accommodate further development within existing settlements.
2.21 This position regarding housing need and lack of land supply (before moving onto Green Belt land), will
be felt more acutely during the drafting of this new Local Plan.

3. NEW LOCAL PLAN: SPATIAL OPTIONS QUESTIONS
3.1 It is noted that in its introductory section the Spatial Options document considers the need to “coordinate the delivery of much needed housing”. It also states that;

“Rochford should consider every opportunity to meet its own housing needs within its own authority
area, with a focus on genuinely affordable housing that meets genuinely local needs”
3.2 Given the extent of Green Belt in this part of South East Essex, it is considered likely that as in Rochford,
surrounding districts will find it difficult to deliver their full quota of required housing land supply within
existing settlements and on brownfield land, i.e. there will be a need to use Green Belt. To this end it is
submitted that they will be unable to offer assistance to Rochford in providing surplus land to accommodate housing delivery. We support the Spatial Options document in the above assertion.
3.3 This will necessitate a review of Green Belt designation to a greater extent than that previously carried out with the adopted Core Strategy. As noted above, Green Belt serves 5 purposes; “to check the
unrestricted sprawl of large built-up areas, to prevent neighbouring towns merging into one another, to
assist in safeguarding the countryside from encroachment, to preserve the setting and special character of historic towns and to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.” It is submitted that where these matters are less acutely felt, and in those areas of lesser
landscape quality, new housing land allocations could be proposed within the currently designated Green Belt, to assist with achieving the necessary housing land supply. The Core Strategy acknowledges this approach;
The term ‘Green Belt’ refers to a planning designation and is not necessarily a description of quality of
the land. Land designated as Green Belt can include, primarily for historical reasons, developed land and
brownfield sites. As such, whilst it is considered that all land currently designated as Green Belt helps achieve the five green belt purposes as set out in the NPPF to at least a degree, some green belt land is less worthy of continued protection.
3.4 This is acknowledged in the New Local Plan: Spatial Options document, which considers 4no. spatial
options for delivery of necessary development and infrastructure. All but Option 1 would necessitate
the use of Green Belt.
Question 5. Do you agree with the settlement hierarchy presented? If not, what changes do you think
are required?
3.6 We support the settlement hierarchy presented. This focuses development at the most appropriate
settlements in the order of their ability to support new development. Rayleigh benefits from a strong existing resident mass and thus has a viability for growth and expansion of businesses and communities. We would submit that the majority of new development, and residential site allocations, should be around Rayleigh.
Question 6. Which of the identified strategy options do you consider should be taken forward in the Plan?
3.7 We support Strategy Option 2 and in particular Option 2a. This option provides a balanced response to the housing need of 7,200 – 10,800 dwellings (delivering between 8,700 to 10,700 dwellings), the necessary mass to support a good level of new infrastructure and facilities, and the need to minimise as much as possible the release of Green Belt for development.
3.8 Option 1 would not deliver the required housing land necessary to respond to the identified housing
need over the course of the Plan, and as discussed, it is considered unlikely that other surrounding districts would be able to assist with additional land. Option 3 would necessitate a significant release of Green Belt and would have a significant impact on the character of the surrounding Green Belt due to the size of a new villages/towns. As with to Option 3, Option 4 would require a sizeable release of Green Belt and significant impact on surrounding land around any new villages/towns.
3.9 Figure 23 of the Spatial Options document provides a Sustainability Appraisal of the various Options and this illustrates the balance that Option 2 provides, albeit it is noted that Option 4 scores best.
However, due to its mix of strategies for the delivery of development we would note a concern that it would pose significant complexities in implementing. In order to achieve the development required the full mix of strategies would be required, and if one were to fail or be delayed (as is a real risk with new villages/towns), a shortfall in housing or employment space could result, putting the Council’s position at risk.
Question 56a. Do you agree with our vision for Rayleigh? Is there anything you feel is missing?
3.10 We support the vision for Rayleigh. It is and should remain the only Tier 1 settlement given its existing
population mass, infrastructure/facilities provision and ability to accommodate significant growth relative to other settlements. The growth and expansion of Rayleigh with urban extensions would generate a sizeable portion of the housing quota required to respond to the identified housing need. Through the development of the majority of those sites submitted for consideration around the edges of Rayleigh, this focal settlement could alleviate pressures on more rural settings and larger swathes of
Green Belt throughout the rest of the district.
Questions 56b, 56c, 56d and 56e.
3.11 It is submitted that land at Call for Sites references CFS044 and CFS256 would offer an opportunity to
contribute to identified housing need delivery in a Green Belt location that could maintain the five purposes of Green Belt and in a location that has reduced landscape quality but is also well screened from surrounding areas. The attached initial Scoping Landscape Statement and Transport Planning Technical Note support that proposal.
3.12 The Council have carried out an initial assessment of these sites, as below.

[SEE DOCUMENT FOR IMAGE]

3.13 Whilst the appraisals above highlight the impact upon Green Belt, as discussed it is submitted that most
virgin sites put forward will impact upon that designation. It is considered that a sequential assessment
of the districts Green Belt would be appropriate in this regard and could highlight those sites that would
have a lesser visual impact and still maintain the purposes of Green Belt as best possible. The above
sites are expected to respond positively in both regards. The accompanying Scoping Landscape Statement concludes thus;
The landscape is subdivided into paddocks and is not of the highest visual quality, but the structure is strong and there are valued elements within it. The site is well contained by woodland and hedgerows, which should be used to inform design work for any forthcoming development proposal. Development of the site would take place within the current Green Belt designation / boundary, but the impact of development upon the openness of the Green Belt would be limited, due to the site's location adjacent to the existing urban area, its location within an enclave of landscape defined by the urban area and the A127, and the fact that the site's character is already enclosed, offering few publicly
accessible viewpoints.
Development of the site would not bring about coalescence of settlement, due to the strong landscape
barrier represented by the A127 itself, and the extensive Pound Wood Nature Reserve to the south of it,
separating the site from Daws Heath. Should the site be brought forward for development, design work should be informed by a full understanding of local landscape and visual character. The enclosed and compartmentalised character of the site should be retained and used as a constraint for design.
3.14 The Sustainability Appraisal also scores the sites low on ‘Existing site access’. However, the
accompanying Transport Planning Technical Note identifies 3no. possible accesses to the site, two of
which would be new accesses. It comments thus;
A number of options have been identified as having good potential for providing vehicle access to the site to unlock its development potential and deliver between 200 and 300 residential dwellings as part of the new Rochford Local Plan.
Providing a sustainable transport link from the site to the north is considered important to unlock the full sustainable development potential of the site as there are a number of local facilities and services on this section of A1015 Eastwood Road including bus stops.
3.15 It is submitted that in other key criteria the sites score well in the Sustainability Appraisal and in
combination would provide a high scoring option as a residential/housing allocation (including market
and affordable).
3.16 It is submitted that generally the area of these sites is well suited to accommodating a moderate
amount of new development. It is well enclosed by existing built form with the edge of Rayleigh to the
immediate north and the A127 to the immediate south. As such it would not lead to an interruption of
open land and countryside to the detriment of the landscape and quality of Green Belt. Furthermore,
this area scores well in terms of its Walking Completeness Score, in particular the two sites identified,
which are adjacent to land scoring of 8-10.
3.17 In combination with other similarly sized sites in this location to the south east of Rayleigh, a good level
of housing land supply could be achieved across numerous parcels (each able to provide in the region
100 to 400 dwellings). This would not necessitate significant new infrastructure but rather upgrades to
existing. Furthermore, the delivery of this volume of dwellings across several parcels would allow for
the retention of important green spaces and structural planting in between, which could serve to
maintain the green character of this urban/rural fringe and complement the Green Belt beyond.
3.18 We Support the allocation of Open Space and Local Wildlife Sites to the east of Rayleigh. It is
submitted that development on or adjacent to these protected sites could negatively impact upon
them, through increased light/air/noise pollution and walker/visitors (in the case of the wildlife sites).
There is an added logic in retaining these sites as open space and wildlife sites (for their intrinsic value)
as they could double as Green Belt.

1. INTRODUCTION
1.1 Rochford District Council is seeking feedback from interested parties on its identified ‘Options’ in the
New Local Plan: Spatial Options document.
1.2 Lee Evans Planning have been instructed to make representations on behalf of Ms Suzanne Redwood,
Mr Roger Lambourne and Mr Colin Humphries.
1.3 Section 2 sets out relevant extant Planning Policy considerations.
1.4 Section 3 reviews and comments on the Spatial Options document, including providing responses to
Questions outlined in the Consultation.

2. CURRENT POLICY POSITION
National Planning Policy Framework
2.1 The National Planning Policy Framework sets out the meaning and role of sustainable development and how planning can help to achieve it. At a very high level, the objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs.
2.2 A rising population and longer life expectancy requires growth and an increase in the volume and
choice of housing. The NPPF identifies the need to complement this growth with high standards of
design and to protect our built, natural and historic environments. The NPPF also highlights the
fundamental role that sustainable development plays in the plan-making and decision making process.
So that sustainable development is pursued in a positive way, at the heart of the Framework is a presumption in favour of sustainable development
2.3 The NPPF serves to provide a framework around which the community and the councils can produce
the local and neighbourhood plans, which reflect the needs and priorities of the community.
The National Planning Policy Framework must be taken into account in preparing the development plan, and is a material consideration in planning decisions.
2.5 Paragraph 8 of the NPPF reiterates the role of the planning system and the contribution it must make to realising sustainable development. Sustainable development has three dimensions to it; economic,
social and environmental.
• an economic objective – to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and
coordinating the provision of infrastructure;
• a social objective – to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering well-designed, beautiful and safe places, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being; and
• an environmental objective – to protect and enhance our natural, built and historic environment; including making effective use of land, improving biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate
change, including moving to a low carbon economy.
2.6 The NPPF considers in further detail the need to protect and improve the quality of the built, natural and historic environment. One aspect of this aim is to widen the choice of quality homes. This can be achieved through the plan-making process, as discussed in paragraph 11.
Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that:
a) all plans should promote a sustainable pattern of development that seeks to: meet the development
needs of their area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects;
b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:
i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or
ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when
assessed against the policies in this Framework taken as a whole.
2.7 Paragraph 60 notes the need to boost the supply of homes through land allocation. To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay.
2.8 Paragraph 61 outlines the approach to determining housing need. The New Local Plan; Spatial Options
document is unclear on the degree to which the duty to cooperate has been explored with neighbouring areas, suggesting that at present the assumption should be made that all identified housing need must be delivered within the district.
To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.
2.9 Each year the local planning authority will identify their supply of specific deliverable sites to provide the next five years of housing with an additional 5% buffer. This will allow for both choice and competition in the market. Developable sites that can accommodate for years 6-10 of the plan period and beyond will also be identified.
2.10 A 10% buffer should be provided “where the local planning authority wishes to demonstrate a five year
supply of deliverable sites through an annual position statement or recently adopted plan, to account for any fluctuations in the market during that year”.
2.11 A 20% buffer should be provided “where there has been significant under delivery of housing over the
previous three years, to improve the prospect of achieving the planned supply”. The NPPG elaborates
by stating that “A 20% buffer will apply to a local planning authority’s five-year land supply if housing delivery falls below 85%”.
2.12 If a five year supply of deliverable housing cannot be demonstrated policies relating to the supply of housing should not be considered to be up-to-date. All housing applications should be considered on the basis of a presumption in favour of sustainable development as has been discussed above. The most recent Authority Monitoring Report (draft 2019-2020), suggests that there exists a district housing need of 1,800 homes over a five year period (equating to 360 homes per year) and that the Council could at that time illustrate a 6.32 year housing land supply at a 5% buffer level, and 5.53 year supply at the 20% buffer, albeit it is noted that this was only draft and requires updating for the 2020-2021 period. The current supply is unknown but the Spatial Options document notes that the need for 360 homes per
year over the course of the Plan (20 years), equating to 7,200 homes total, remains. This figure does not include for assisting other districts in the duty to cooperate or any 5/20% buffer, so could well be higher. Notwithstanding this, there is a clear need to increase the allocation of housing land in the new Local Plan to illustrate the potential for 7,200 homes to be delivered.
2.13 Paragraph 73 highlights the opportunity for larger scale development and the benefits of this approach
in achieving the necessary supply of housing. It is possible that new settlements or extensions to
existing settlements can provide a route to sustainable development.
The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities (including a genuine choice of transport modes).
2.14 Paragraph 23 notes that Local Plans should plan positively for development by allocating sites for
development and identify land where development would be inappropriate due to its environmental or historic significance.
Broad locations for development should be indicated on a key diagram, and landuse designations and allocations identified on a policies map. Strategic policies should provide a clear strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period, in line with the presumption in favour of sustainable development. This should include planning or and allocating sufficient sites to deliver the strategic priorities of the area
2.15 Paragraph 138 of the NPPF refers to the purposes of the Green Belt;
Green Belt serves five purposes:
a) to check the unrestricted sprawl of large built-up areas;
b) to prevent neighbouring towns merging into one another;
c) to assist in safeguarding the countryside from encroachment;
d) to preserve the setting and special character of historic towns; and
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
2.16 Local Plans will be examined by an independent inspector before they are adopted. To be considered
ready for adoption they will need to be shown to be ‘sound’, as per paragraph 35 of the NPPF;
Local plans and spatial development strategies are examined to assess whether they have been
prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are
‘sound’ if they are:
a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
c) Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant. Rochford District Core Strategy and the Allocations Plan
2.17 The key strategic documents in the local development plan are the adopted Core Strategy 2011 and the Allocations Plan 2014. These are both dated documents and would be considered out of date where
the content conflicts with NPPF policy. Nonetheless, they provide a useful basis against which to subsequently consider the options in the New Local Plan consultation.
2.18 The following exerts are of interest;
District
2.41 “Failure to provide affordable housing that meets the needs of the District’s residents may lead to
continued out-migration, to the detriment of the vitality of local communities.” (p31)
Rayleigh
“The largest settlement is Rayleigh which, in 2001, was home to 30,196 people (38% of the District’s
residents at that time).” (p28)
Housing Development
2.39 “As well as directing housing growth to areas of need/demand, and away from unsustainable
locations subject to constraints, the Council must consider the relationship of housing growth to areas
of employment growth.” (p30)
Vision – Medium/Long Term “A range of high-quality, sustainable new dwellings that meet the needs
of local people of all social groups are in place and integrated into communities. The vast majority of
the District’s Green Belt remains undeveloped. New infrastructure has accompanied new residential
development, meeting the need of local communities.” (p41)
Policy H1 – the efficient use of land for housing
“The remaining housing requirement that cannot be delivered through the redevelopment of appropriate previously developed land will be met through extensions to the residential envelopes of existing settlements as outlined in Policy H2.” (p45)
The Green Belt
Housing Objective “Prioritise the redevelopment of appropriate brownfield sites for housing, to minimise the release of Green Belt land for development” (p41).
“In order to fulfil the requirements of the East of England Plan and to meet the housing need of the District, the Council is required to allocate additional land for residential development, including land, which is currently allocated as Green Belt, due to the limited supply” (p45).
“it must be also mindful of the need to maintain Green Belt as far as possible.” (p46)
2.19 The extant Core Strategy outlines a strong protection of the Green Belt, as per national policy. However, this was predicated on an old housing need and supply, which is now out of line with current demand
and what can be achieved through existing permissions, allocations, brownfield sites and windfall forecasts. Rayleigh is considered a focal settlement and one that has both a sizeable population already and the infrastructure to service those residents.
2.20 Notwithstanding the above, the Council recognised the need to review the designation of the Green Belt in the face of the relatively low housing need at the time the Core Strategy was drafted. It states;
The Council will continue to support the principles of restricting development in the Green Belt, as set out in PPG2, and will preserve the character and openness of the Green Belt. However, a small proportion of the District’s Green Belt will have to have its designation reviewed to allow the development of additional housing and business premises, taking account of the very limited
opportunities to accommodate further development within existing settlements.
2.21 This position regarding housing need and lack of land supply (before moving onto Green Belt land), will
be felt more acutely during the drafting of this new Local Plan.

3. NEW LOCAL PLAN: SPATIAL OPTIONS QUESTIONS
3.1 It is noted that in its introductory section the Spatial Options document considers the need to “coordinate the delivery of much needed housing”. It also states that;

“Rochford should consider every opportunity to meet its own housing needs within its own authority
area, with a focus on genuinely affordable housing that meets genuinely local needs”
3.2 Given the extent of Green Belt in this part of South East Essex, it is considered likely that as in Rochford,
surrounding districts will find it difficult to deliver their full quota of required housing land supply within
existing settlements and on brownfield land, i.e. there will be a need to use Green Belt. To this end it is
submitted that they will be unable to offer assistance to Rochford in providing surplus land to accommodate housing delivery. We support the Spatial Options document in the above assertion.
3.3 This will necessitate a review of Green Belt designation to a greater extent than that previously carried out with the adopted Core Strategy. As noted above, Green Belt serves 5 purposes; “to check the
unrestricted sprawl of large built-up areas, to prevent neighbouring towns merging into one another, to
assist in safeguarding the countryside from encroachment, to preserve the setting and special character of historic towns and to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.” It is submitted that where these matters are less acutely felt, and in those areas of lesser
landscape quality, new housing land allocations could be proposed within the currently designated Green Belt, to assist with achieving the necessary housing land supply. The Core Strategy acknowledges this approach;
The term ‘Green Belt’ refers to a planning designation and is not necessarily a description of quality of
the land. Land designated as Green Belt can include, primarily for historical reasons, developed land and
brownfield sites. As such, whilst it is considered that all land currently designated as Green Belt helps achieve the five green belt purposes as set out in the NPPF to at least a degree, some green belt land is less worthy of continued protection.
3.4 This is acknowledged in the New Local Plan: Spatial Options document, which considers 4no. spatial
options for delivery of necessary development and infrastructure. All but Option 1 would necessitate
the use of Green Belt.
Question 5. Do you agree with the settlement hierarchy presented? If not, what changes do you think
are required?
3.6 We support the settlement hierarchy presented. This focuses development at the most appropriate
settlements in the order of their ability to support new development. Rayleigh benefits from a strong existing resident mass and thus has a viability for growth and expansion of businesses and communities. We would submit that the majority of new development, and residential site allocations, should be around Rayleigh.
Question 6. Which of the identified strategy options do you consider should be taken forward in the Plan?
3.7 We support Strategy Option 2 and in particular Option 2a. This option provides a balanced response to the housing need of 7,200 – 10,800 dwellings (delivering between 8,700 to 10,700 dwellings), the necessary mass to support a good level of new infrastructure and facilities, and the need to minimise as much as possible the release of Green Belt for development.
3.8 Option 1 would not deliver the required housing land necessary to respond to the identified housing
need over the course of the Plan, and as discussed, it is considered unlikely that other surrounding districts would be able to assist with additional land. Option 3 would necessitate a significant release of Green Belt and would have a significant impact on the character of the surrounding Green Belt due to the size of a new villages/towns. As with to Option 3, Option 4 would require a sizeable release of Green Belt and significant impact on surrounding land around any new villages/towns.
3.9 Figure 23 of the Spatial Options document provides a Sustainability Appraisal of the various Options and this illustrates the balance that Option 2 provides, albeit it is noted that Option 4 scores best.
However, due to its mix of strategies for the delivery of development we would note a concern that it would pose significant complexities in implementing. In order to achieve the development required the full mix of strategies would be required, and if one were to fail or be delayed (as is a real risk with new villages/towns), a shortfall in housing or employment space could result, putting the Council’s position at risk.
Question 56a. Do you agree with our vision for Rayleigh? Is there anything you feel is missing?
3.10 We support the vision for Rayleigh. It is and should remain the only Tier 1 settlement given its existing
population mass, infrastructure/facilities provision and ability to accommodate significant growth relative to other settlements. The growth and expansion of Rayleigh with urban extensions would generate a sizeable portion of the housing quota required to respond to the identified housing need. Through the development of the majority of those sites submitted for consideration around the edges of Rayleigh, this focal settlement could alleviate pressures on more rural settings and larger swathes of
Green Belt throughout the rest of the district.
Questions 56b, 56c, 56d and 56e.
3.11 It is submitted that land at Call for Sites references CFS044 and CFS256 would offer an opportunity to
contribute to identified housing need delivery in a Green Belt location that could maintain the five purposes of Green Belt and in a location that has reduced landscape quality but is also well screened from surrounding areas. The attached initial Scoping Landscape Statement and Transport Planning Technical Note support that proposal.
3.12 The Council have carried out an initial assessment of these sites, as below.

[SEE DOCUMENT FOR IMAGE]

3.13 Whilst the appraisals above highlight the impact upon Green Belt, as discussed it is submitted that most
virgin sites put forward will impact upon that designation. It is considered that a sequential assessment
of the districts Green Belt would be appropriate in this regard and could highlight those sites that would
have a lesser visual impact and still maintain the purposes of Green Belt as best possible. The above
sites are expected to respond positively in both regards. The accompanying Scoping Landscape Statement concludes thus;
The landscape is subdivided into paddocks and is not of the highest visual quality, but the structure is strong and there are valued elements within it. The site is well contained by woodland and hedgerows, which should be used to inform design work for any forthcoming development proposal. Development of the site would take place within the current Green Belt designation / boundary, but the impact of development upon the openness of the Green Belt would be limited, due to the site's location adjacent to the existing urban area, its location within an enclave of landscape defined by the urban area and the A127, and the fact that the site's character is already enclosed, offering few publicly
accessible viewpoints.
Development of the site would not bring about coalescence of settlement, due to the strong landscape
barrier represented by the A127 itself, and the extensive Pound Wood Nature Reserve to the south of it,
separating the site from Daws Heath. Should the site be brought forward for development, design work should be informed by a full understanding of local landscape and visual character. The enclosed and compartmentalised character of the site should be retained and used as a constraint for design.
3.14 The Sustainability Appraisal also scores the sites low on ‘Existing site access’. However, the
accompanying Transport Planning Technical Note identifies 3no. possible accesses to the site, two of
which would be new accesses. It comments thus;
A number of options have been identified as having good potential for providing vehicle access to the site to unlock its development potential and deliver between 200 and 300 residential dwellings as part of the new Rochford Local Plan.
Providing a sustainable transport link from the site to the north is considered important to unlock the full sustainable development potential of the site as there are a number of local facilities and services on this section of A1015 Eastwood Road including bus stops.
3.15 It is submitted that in other key criteria the sites score well in the Sustainability Appraisal and in
combination would provide a high scoring option as a residential/housing allocation (including market
and affordable).
3.16 It is submitted that generally the area of these sites is well suited to accommodating a moderate
amount of new development. It is well enclosed by existing built form with the edge of Rayleigh to the
immediate north and the A127 to the immediate south. As such it would not lead to an interruption of
open land and countryside to the detriment of the landscape and quality of Green Belt. Furthermore,
this area scores well in terms of its Walking Completeness Score, in particular the two sites identified,
which are adjacent to land scoring of 8-10.
3.17 In combination with other similarly sized sites in this location to the south east of Rayleigh, a good level
of housing land supply could be achieved across numerous parcels (each able to provide in the region
100 to 400 dwellings). This would not necessitate significant new infrastructure but rather upgrades to
existing. Furthermore, the delivery of this volume of dwellings across several parcels would allow for
the retention of important green spaces and structural planting in between, which could serve to
maintain the green character of this urban/rural fringe and complement the Green Belt beyond.
3.18 We Support the allocation of Open Space and Local Wildlife Sites to the east of Rayleigh. It is
submitted that development on or adjacent to these protected sites could negatively impact upon
them, through increased light/air/noise pollution and walker/visitors (in the case of the wildlife sites).
There is an added logic in retaining these sites as open space and wildlife sites (for their intrinsic value)
as they could double as Green Belt.